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    <title>2018 (3) TMI 388 - KERALA HIGH COURT</title>
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    <description>Proceedings that substantively challenge a Tax Recovery Officer&#039;s order under the Second Schedule, including connected suit, appeal, review and writ steps, may be treated as excludable for computing the Rule 68B limitation for sale of attached property, so the fresh attachment was not time-barred. A writ challenge to the fresh attachment and consequential notices was also held unsuitable for Article 226 relief where the petitioner&#039;s title arose from post-attachment transfers that were void against the attachment, and where discretionary relief would reward conduct inconsistent with an earlier undertaking to clear arrears. On those grounds, the recovery action was left undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=356685</link>
      <description>Proceedings that substantively challenge a Tax Recovery Officer&#039;s order under the Second Schedule, including connected suit, appeal, review and writ steps, may be treated as excludable for computing the Rule 68B limitation for sale of attached property, so the fresh attachment was not time-barred. A writ challenge to the fresh attachment and consequential notices was also held unsuitable for Article 226 relief where the petitioner&#039;s title arose from post-attachment transfers that were void against the attachment, and where discretionary relief would reward conduct inconsistent with an earlier undertaking to clear arrears. On those grounds, the recovery action was left undisturbed.</description>
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