https://www.taxtmi.com/caselaws?id=24883 Income accrued in the accounting year before the operative date of the notification extending the Income-tax Act to the continental shelf and exclusive economic zone was held not taxable in the later assessment year, absent an express deeming provision making the extension retrospective. The court also noted that section 226(3) garnishee recovery applies only where the noticee owes money to the assessee or holds it on the assessee's account; sums payable by ONGC to a third party under a separate contract did not satisfy that . The recovery notice was therefore invalid, and the attached amount had to be released. en-us Wed, 06 Apr 1988 00:00:00 +0530 Sat, 23 Jan 2010 10:21:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=24883 Income accrued in the accounting year before the operative date of the notification extending the Income-tax Act to the continental shelf and exclusive economic zone was held not taxable in the later assessment year, absent an express deeming provision making the extension retrospective. The court also noted that section 226(3) garnishee recovery applies only where the noticee owes money to the assessee or holds it on the assessee's account; sums payable by ONGC to a third party under a separate contract did not satisfy that . The recovery notice was therefore invalid, and the attached amount had to be released. Case-Laws Income Tax Wed, 06 Apr 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=24883