https://www.taxtmi.com/caselaws?id=9041 The Income-tax Act's self-contained recovery machinery governed the dispute, so a civil court could not entertain a parallel challenge to notices issued for tax arrears. Questions relating to execution, discharge or satisfaction of the recovery certificate had to be decided by the Tax Recovery Officer under the Second Schedule, except on a fraud allegation, and section 232 did not displace that special procedure. The bank also failed to show that the judgment-debtor was properly affected or that the matter was a representative proceeding under section 47 CPC. The challenge was therefore outside civil court competence and the appeal was incompetent. en-us Thu, 18 May 1972 00:00:00 +0530 Thu, 18 Jun 2009 18:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9041 The Income-tax Act's self-contained recovery machinery governed the dispute, so a civil court could not entertain a parallel challenge to notices issued for tax arrears. Questions relating to execution, discharge or satisfaction of the recovery certificate had to be decided by the Tax Recovery Officer under the Second Schedule, except on a fraud allegation, and section 232 did not displace that special procedure. The bank also failed to show that the judgment-debtor was properly affected or that the matter was a representative proceeding under section 47 CPC. The challenge was therefore outside civil court competence and the appeal was incompetent. Case-Laws Income Tax Thu, 18 May 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9041