https://www.taxtmi.com/caselaws?id=49303 A writ petition under article 226 challenging a tax levy was treated as a civil proceeding for article 133(1) because it concerned civil rights and relief against their infringement, not the form of procedure, so the certificate was competent. A retrospective proviso to section 18A(6) of the 1922 Income-tax Act, read with rule 48 from its effective date, meant that failure to charge interest in the assessment order was an error apparent on the record. Rectification under section 35 was therefore available, and the challenge to the interest demand failed. en-us Fri, 07 May 1965 00:00:00 +0530 Tue, 19 Aug 2014 20:21:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49303 A writ petition under article 226 challenging a tax levy was treated as a civil proceeding for article 133(1) because it concerned civil rights and relief against their infringement, not the form of procedure, so the certificate was competent. A retrospective proviso to section 18A(6) of the 1922 Income-tax Act, read with rule 48 from its effective date, meant that failure to charge interest in the assessment order was an error apparent on the record. Rectification under section 35 was therefore available, and the challenge to the interest demand failed. Case-Laws Income Tax Fri, 07 May 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49303