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of <h1>Tax Recovery Officers retain broad discretionary power to cancel recovery certificates under Section 224 and Clause 413(4)</h1> The Income Tax Bill 2025's Clause 413(4) and the Income-tax Act 1961's Section 224 both govern tax recovery certificates issued by Tax Recovery Officers. Both provisions grant officers discretionary power to cancel certificates 'for any reason' deemed necessary or correct clerical/arithmetical errors. The taxpayer cannot challenge certificate validity on any grounds, ensuring administrative finality and preventing dilatory litigation. The provisions aim to streamline tax recovery while maintaining limited correction mechanisms. Clause 413(4) appears within a more comprehensive recovery framework compared to the standalone Section 224, though their substantive effects remain nearly identical, preserving broad administrative discretion subject to judicial review for jurisdictional errors.
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