https://www.taxtmi.com/caselaws?id=40214 Section 11 of the Special Court Act confines priority over attached assets to tax liabilities that arose during the statutory period and were finally assessed and quantified. A mere charging liability or uncrystallised claim does not qualify, and the priority does not extend to later liabilities. The Special Court cannot reopen tax assessments, but it may exceptionally regulate the amount payable from attached funds where there is serious miscarriage of justice, fraud, collusion, or a grossly disproportionate best judgment assessment. Penalty and interest are distinct from tax and fall outside section 11(2)(a); later liabilities may be recovered otherwise in accordance with law or dealt with from surplus under section 11(2)(c). en-us Wed, 13 May 1998 00:00:00 +0530 Thu, 03 Jul 2014 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=40214 Section 11 of the Special Court Act confines priority over attached assets to tax liabilities that arose during the statutory period and were finally assessed and quantified. A mere charging liability or uncrystallised claim does not qualify, and the priority does not extend to later liabilities. The Special Court cannot reopen tax assessments, but it may exceptionally regulate the amount payable from attached funds where there is serious miscarriage of justice, fraud, collusion, or a grossly disproportionate best judgment assessment. Penalty and interest are distinct from tax and fall outside section 11(2)(a); later liabilities may be recovered otherwise in accordance with law or dealt with from surplus under section 11(2)(c). Case-Laws Income Tax Wed, 13 May 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=40214