Tax recovery certificates enable arrears recovery through asset attachment, sale, or receivership while limiting challenges during recovery proceedings.

Section 413 enables recovery of tax arrears through a tax recovery certificate issued for an assessee in default or deemed to be in default. Recovery may proceed through attachment and sale of movable or immovable property or appointment of a receiver. Certificate-based recovery may operate alongside other recovery modes, and the assessee cannot challenge the certificate's correctness during recovery proceedings. The certificate may be cancelled or corrected for clerical or arithmetical mistakes. Specified property transferred without adequate consideration to close family members is also available for recovery.

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