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    <title>2026 (2) TMI 213 - MADRAS HIGH COURT</title>
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    <description>For Rule 68B of the Second Schedule to the Income-tax Act, limitation for sale of attached immovable property runs from the end of the financial year in which the assessment order becomes truly final, meaning it can no longer be set aside, modified, or revised. Where the assessment order was still open to Supreme Court interference until the special leave petition was dismissed, finality was reached only on that dismissal. On that basis, the three-year period began from 31 March 2016, and the sale proclamation issued in June 2018 fell within time. The ancillary objection based on the second certificate did not change the result.</description>
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