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    <title>1997 (8) TMI 541 - Supreme Court</title>
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    <description>Section 45B of the Employees State Insurance Act, 1948 was treated as a procedural provision governing only the mode of recovery. Because it did not create or extinguish liability, but merely enabled recovery of an existing unpaid contribution as arrears of land revenue, it could apply to contributions that had fallen due before the section came into force and remained unpaid when recovery was initiated. The recovery notices were therefore valid, and the mechanism under Section 45B was held applicable to the unpaid contributions in question.</description>
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      <title>1997 (8) TMI 541 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=296204</link>
      <description>Section 45B of the Employees State Insurance Act, 1948 was treated as a procedural provision governing only the mode of recovery. Because it did not create or extinguish liability, but merely enabled recovery of an existing unpaid contribution as arrears of land revenue, it could apply to contributions that had fallen due before the section came into force and remained unpaid when recovery was initiated. The recovery notices were therefore valid, and the mechanism under Section 45B was held applicable to the unpaid contributions in question.</description>
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