Tax recovery cannot proceed before service of demand orders; appeal time starts only after valid service.

Coercive tax recovery by attachment of a bank account is impermissible until the assessment and penalty orders have been validly served on the assessee. On the facts, because service had not been effected, immediate recovery steps were not justified at that stage. The court also confirmed that the limitation period for challenging the orders would begin only from the date of valid service, preserving the petitioner's statutory appellate remedy. The assessment and penalty orders were not set aside, and the authorities retained the right to proceed with recovery in accordance with law after service and after the assessee had an opportunity to appeal.

---

---

Issues: Whether coercive recovery by attachment of the bank account was permissible when the assessment and penalty orders had not been served on the petitioner, and whether the time to challenge those orders would commence only upon service.

Analysis: Recovery proceedings cannot be pursued through coercive measures unless the assessee has been served with the assessment order. On the facts, the assessment order had not been served, so attachment of the bank account and other recovery steps were not justified at that stage. At the same time, the assessment order itself was not set aside, and the respondents retained the right to recover the dues in accordance with law after service of the orders and after the petitioner had an opportunity to avail the appellate remedy.

Conclusion: Coercive recovery was held impermissible until service of the assessment and penalty orders, and the period for filing an appeal was directed to run from the date of such service.

Final Conclusion: The writ petition was disposed of by protecting the petitioner from immediate recovery action, directing service of the orders, and preserving the statutory right of challenge thereafter.

Ratio Decidendi: Coercive tax recovery cannot be initiated before service of the demand order on the assessee, and the limitation to challenge the order begins only from valid service.

---