Limitation for tax recovery under Section 73 remitted for fresh adjudication subject to 50% predeposit and lifting attachment

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....Limitation for issuance of a tax recovery order under Section 73 was considered alongside an extension by notification; because the impugned order was ex parte after the petitioner failed to reply to the show cause notice, the court remitted the matter for fresh adjudication on merits. The respondent must give notice before passing any fresh order. Proceeding will continue only if the petitioner deposits 50% of the disputed tax in cash or from its electronic cash ledger within 30 days; bank attachment will be lifted upon that deposit, and failure to comply permits recovery as if the petition were dismissed.....