The Assessee was a partnership firm engaged in the business of courier services and had jewellery and articles worth ` 3,06,16,110/-requisitioned under section 132A from persons carrying the firm’s parcels. The Assessee filed an application under section 132B within the prescribed time, explaining that the assets were stock-in-trade and providing audited accounts. No response was received and the assets remained unreleased well beyond the 120-day statutory period. During the pendency of the writ petition the AO passed an order rejecting the application on the ground that assessment for A.Y. 2023-24 had been completed and a demand of ` 2,96,26,750/-had crystallized. The Assessee challenged this order. The Court allowed the writ petition and decided in favour of the Assessee and held that the legislative intent under section 132B was clear, once a taxpayer makes an application within the prescribed time and the conditions are satisfied, the AO has no choice but to release the seized assets within 120 days of the last authorisation. The AO is not at liberty to await crystallization of the future tax liability of the assessment year in which the assets were seized. The existing liability to be considered is only as it stood on the date of the application, not a demand subsequently raised after assessments are finalized two years later. Retaining seized assets beyond 120 days to await future assessment demands substantially dilutes the rigors of section 132B and frustrates its legislative intent. The impugned order was quashed and the Revenue was directed to release the seized assets within four weeks.  (AY 2022-23)