Pabitra Kumar Hira v. UOI (2024)467 ITR 108 / 167 taxmann.com 664 (Gauhati)(HC)

S. 226 : Collection and recovery-Modes of recovery-Recovery of tax-Attachment and sale of immovable property-Limitation-Assessment order was passed in final year ending on 31-3-2010-Attachment of property on 20-12-2018 and proclamation of sale on 27-3-2019-Barred by limitation [S. 245-I, Chapter XVII of the Income-tax Act, 1961, Second Schedule, R. 68B, Art. 226]

Held, that in view of the revision order and the consequential revised assessment order it became conclusive in terms of the provisions of Chapter XX to the Income-tax Act, 1961, in the financial year ending March 31, 2010. In the facts and circumstances of the case, rule 68B would apply. The attachment of the immovable property was made on December 20, 2018 and the notice of proclamation of sale was made on March 27, 2019. The attachment and proclamation of sale were barred by limitation. (BP.  1997-98 to 2003-04)

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