Limitation period for sale of attached property not to be reckoned from date of intimation u/s 143(1)

INCOME TAX: Where return was acknowledged under section 143(1) and final assessment order was passed under section 143(3) against which appeals were still pending, it could not be said that order became conclusive; period of limitation for selling attached immovable property would reckon only from date, on which order would become conclusive

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