CHAMPA KUMARI SINGHI & ORS. vs THE MEMBER BOARD OF REVENUE, WEST BENGALAND OTHERS

The Supreme Court held that the certificates issued under Section 46(2) of the Indian Income Tax Act, 1922 were not barred by limitation under Section 47(1). The Court reasoned that the assessment order incorporated the agreement for payment by instalments, making the entire amount exigible upon default of a single instalment. The Court clarified that the time for limitation should be calculated from the date of the last instalment, thus allowing recovery proceedings despite the default occurring more than one year prior to the last instalment due date.