Recovery limitation under the Agricultural Income-tax Act turns on timely issue of the certificate, not later collection steps.

Limitation for recovery under the Agricultural Income-tax Act is satisfied if the certificate issued under Section 41(3) commences recovery within the statutory period under Section 41(4); later steps taken through the Revenue Recovery Act do not become time-barred merely because they are completed later. On the stated facts, the demand notice followed the assessment and the certificate was issued within three years of the latest payment date, so the initiation of recovery was valid and the limitation challenge failed.

---

---

Issues: Whether recovery proceedings initiated under the Revenue Recovery Act were barred by limitation under Section 41(4) of the Agricultural Income-tax Act, 1950, where the certificate under Section 41(3) had been issued within three years from the latest date fixed for payment under the demand notice.

Analysis: The limitation under Section 41(4) applies to the commencement of recovery proceedings, and the certificate issued under Section 41(3) is the step that sets such proceedings in motion. Once that certificate is issued within the prescribed period, subsequent recovery steps taken through the Revenue Recovery Act do not become time-barred merely because they are completed later. On the facts, the notice of demand followed the assessment, and the certificate was issued within three years of the relevant payment date. The later delay in actual recovery did not affect the validity of the initiation of recovery proceedings.

Conclusion: The limitation objection failed, and the challenge to the recovery orders was rejected.

Ratio Decidendi: For recovery under the Agricultural Income-tax Act, limitation is satisfied if the certificate commencing recovery is issued within the statutory period; later recovery through the Revenue Recovery Act may continue even after that period expires.

---