According to learned Government Pleader, the plea of learned counsel for the petitioner that the petitioner’s recall petition is pending appears to be not sustainable in the eye of law. He highlights that the writ petition, which was filed by the petitioner against the assessment order, was dismissed as withdrawn long back on 19.10.2016. In the meanwhile, all steps have taken. The petitioner in view of assessment order was issued penalty showcause notice in the year 2017 and finally penalty order was also passed on 31.03.2018. He submits that after final penalty order was passed, to the reasons best known to the petitioner, it has pleaded that it has filed a recall petition on 05.03.2019. According to learned Government Pleader, such recall petition even it is filed may not be entertained due to the simple reason that by filing of such recall petition in the year 2019, the petitioner tried to make a prayer for recall of an order, which was passed way back on 19.10.2016. He submits that there is principle of limitation also. In such circumstances, moreover, the recall petition even as per the pleading has not been assigned any number by this Court. According to him, the so-called recall petition appears to be an imagination of the petitioner only and on the core explanation, which has been taken by the respondents, which has come to the stage of sale of the properties, may not be interfered with.
