Scope of Sec.224.

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....e TRO is not competent to hear the objections of the assessee and to vary the demand certified to him. Therefore when the recovery proceedings are initiated by the TRO the assessee has still to approach the ITO concerned to give effect to rectification/appeal effect etc. Even in cases where the ITO modifies the demand by giving credit for pre-paid taxes or by passing an order of rectification or g....

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.... certificate, there is no express bar on the TRO to satisfy himself about the correctness of the certified demand. Under clause 4 of 2nd schedule the TRO can call upon an assessee to pay the demand within a specified time or within such further time as the TRO may grant in his discretion. This power to grant further time would imply that the TRO can either stay the recovery for a specified time or....