Limitation-barred final order set aside, with consequential bank attachment revoked in favour of the assessee.

A final order passed after the expiry of the permissible limitation period was liable to be interfered with where the parties accepted the delay and a prior court order covered the same point. Once the final order was set aside, the consequential bank attachment could not survive and stood revoked in favour of the assessee. The ruling turns on the operative effect of limitation on the validity of the final order and on the collapse of follow-on attachment once the underlying order is annulled.

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Issues: Whether the final order dated 01.05.2024, having been passed beyond the last date of limitation, was liable to be set aside and the consequential bank attachment revoked.

Analysis: The parties accepted that the impugned final order was passed after the permissible period had expired. In view of the consensus and the applicability of the prior order of the Court on the same point, the impugned order was liable to be interfered with. Once the final order was set aside, the consequential attachment could not survive.

Conclusion: The final order was set aside and the consequential bank attachment, if any, stood revoked, in favour of the assessee.

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