Cash seized during search cannot be adjusted against advance-tax liability

As per provisions of section 132B of the Act the assets seized u/s 132 or requisitioned u/s 132A may be adjusted towards the amount of any “existing liability”. The Explanation 2 attach to section 132B of the Act clarifies that for removal of doubts it is hereby declared that the “existing liability” does not include “advance tax” payable in accordance with the provisions of part C of Chapter XVII of the Act. The ld. Counsel for the assessee submitted that Explanation 2 to section 132B is of prospective effect because it was inserted by the Finance Act, 2013...