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Issues: Whether the notification extending the period under rule 68B was valid and, if not, whether the auction sale conducted after the prescribed period was time-barred.
Analysis: Rule 68B, inserted by Parliament, prescribed a three-year period for sale of attached property. The notification issued by the Board purported to extend that period, but no power under section 119 authorised the Board to amend a statutory rule enacted by Parliament. Rule 94 did not justify such a substantive alteration. The notified extension was therefore without effect, and the sale had to be tested on the basis of the original three-year period.
Conclusion: The notification was invalid and the auction sale was beyond time; the sale was set aside in favour of the assessee.