https://www.taxtmi.com/caselaws?id=99832 A tax recovery suit cannot be maintained unless the assessment order is made against the very person or entity sought to be made liable. Here, the assessment notice and order were treated as having proceeded against a third party rather than the defendants or the firm said to owe the tax, so the foundational precondition for civil liability was absent. Subsequent conduct relied on by the claimant did not amount to waiver of that defect. The result was that the assessment could not sustain the recovery suit against the defendants, and their objection succeeded. en-us Fri, 03 Apr 1964 00:00:00 +0530 Mon, 23 Sep 2013 13:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=99832 A tax recovery suit cannot be maintained unless the assessment order is made against the very person or entity sought to be made liable. Here, the assessment notice and order were treated as having proceeded against a third party rather than the defendants or the firm said to owe the tax, so the foundational precondition for civil liability was absent. Subsequent conduct relied on by the claimant did not amount to waiver of that defect. The result was that the assessment could not sustain the recovery suit against the defendants, and their objection succeeded. Case-Laws VAT and Sales Tax Fri, 03 Apr 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=99832