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    <title>1967 (4) TMI 3 - Supreme Court</title>
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    <description>Section 46(5A) of the Indian Income-tax Act, 1922 was construed as a recovery provision directed only at persons in a subsisting relationship with the assessee, where money is due, may become due, or is held for the assessee. The Court rejected a broad reading that would permit speculative notices to strangers based only on a remote future possibility of liability, treating the objection clause as limited to denial of present indebtedness or possession. On that construction, the notice could not be enforced against the respondent in respect of amounts already paid to the assessee, and the demand was invalid; the appeal was dismissed and the High Court&#039;s view was sustained.</description>
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    <pubDate>Wed, 05 Apr 1967 00:00:00 +0530</pubDate>
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      <title>1967 (4) TMI 3 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5014</link>
      <description>Section 46(5A) of the Indian Income-tax Act, 1922 was construed as a recovery provision directed only at persons in a subsisting relationship with the assessee, where money is due, may become due, or is held for the assessee. The Court rejected a broad reading that would permit speculative notices to strangers based only on a remote future possibility of liability, treating the objection clause as limited to denial of present indebtedness or possession. On that construction, the notice could not be enforced against the respondent in respect of amounts already paid to the assessee, and the demand was invalid; the appeal was dismissed and the High Court&#039;s view was sustained.</description>
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      <pubDate>Wed, 05 Apr 1967 00:00:00 +0530</pubDate>
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