https://www.taxtmi.com/caselaws?id=37841 The court held that the ITO lacked jurisdiction to enforce payment under Section 226(3) of the I.T. Act due to the time-barred debt. Garnishee proceedings were deemed invalid as the debt had expired, precluding a debtor-creditor relationship. Consequently, the petitioner could not be treated as an "assessee in default," and the attachment of her properties was invalidated. The court ruled in favor of the petitioner, granting the writ petition and awarding costs. en-us Fri, 23 Dec 1977 00:00:00 +0530 Thu, 01 Apr 2010 13:15:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37841 The court held that the ITO lacked jurisdiction to enforce payment under Section 226(3) of the I.T. Act due to the time-barred debt. Garnishee proceedings were deemed invalid as the debt had expired, precluding a debtor-creditor relationship. Consequently, the petitioner could not be treated as an "assessee in default," and the attachment of her properties was invalidated. The court ruled in favor of the petitioner, granting the writ petition and awarding costs. Case-Laws Income Tax Fri, 23 Dec 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37841