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    <description>Orders under provisions dealing with recovery of tax from a third party are time barred where issued beyond a reasonable period; courts infer that reasonable time from the tax statute&#039;s scheme and prior precedent, commonly treated as four years by several High Courts and reflected later in legislative limitation changes, so that orders beyond that period may be set aside. The Tribunal applied this principle to quash an assessing officer&#039;s order as beyond the reasonable period, resulting in relief for the taxpayer. The text also notes that Revenue, having accepted a High Court&#039;s legal declaration in one case, cannot ordinarily reopen it against other taxpayers without just cause.</description>
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