Para 80 of Minutes of Commissioner's conference, 1976.

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....n should be taken to effect recovery of preassessment taxes and post-assessment taxes. In particular penalties u/s 221 should invariably be levied before any other coercive step is taken. The powers of distraint available u/s 226(5) should be more effectively exercised in view of the clear instructions of the Board contained in D.O. letter No. 405/379/72-ITCC dated 12-12-1972". A copy of the gu....