Garnishee recovery requires prior adjudication, consideration of taxpayer replies, and a personal hearing before coercive recovery proceeds.

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....Garnishee recovery action carrying serious civil consequences requires prior adjudication where the taxpayer has raised disputed tax particulars and submitted replies. The material states that recovery should not proceed without considering those replies, providing a personal hearing, and issuing a reasoned order consistent with principles of natural justice. The recovery notice was kept in abeyance pending adjudication, with the authority required to hear the taxpayer and decide the matter within the stipulated period. All substantive merits remained open for determination.....