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of <h1>Tax Recovery Officers can cancel certificates and fix errors but taxpayers cannot challenge certificate validity during recovery</h1> Section 224 of the Income Tax Act, 1961 governs the validity and modification of tax recovery certificates. The provision prohibits taxpayers from disputing the correctness of certificates issued by Tax Recovery Officers on any grounds. However, Tax Recovery Officers retain discretionary authority to cancel certificates when deemed necessary or correct clerical and arithmetical errors. The section underwent significant amendment in 1987, streamlining the original three-subsection structure into a single provision. Previously, the law distinguished between powers of Assessing Officers and Tax Recovery Officers, with specific procedures for certificate withdrawal and correction. The amendment consolidated these provisions while maintaining the fundamental principle that certificates cannot be challenged by taxpayers during recovery proceedings, ensuring efficient tax collection while preserving administrative flexibility for necessary corrections.
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