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Issues: Whether the notice in Form-I issued under Section 8 of the Andhra Pradesh Revenue Recovery Act, 1864 was invalid for non-compliance with the prescribed procedure and blanks in the notice, in a case where the tax liability had already been assessed and served on the assessee.
Analysis: Section 8 prescribes a three-step procedure for seizure and sale of movable property for arrears of revenue, beginning with a demand in writing specifying the defaulter, the arrear and the date of fall due. The notices and assessment orders preceding the recovery action showed that the tax and penalty liabilities had already been provisionally determined, confirmed, and served on the petitioner. Once the liability had been determined through due process and had attained finality, the petitioner could not claim ignorance of the dues merely because the Form-I notice contained blanks or because the amount demanded was higher than an earlier arrears notice. The purpose of Section 8 is to inform an unaware defaulter, not to repeat what is already known and adjudicated.
Conclusion: The Form-I demand notice was valid and no irregularity was made out in the recovery proceedings.