but only the consequential steps taken by the authorities for execution of the recovery certif i cate so issued . To my mind, that would not extricate the said respondents from the liability fastened under sub-section (2A) referred to above . It will be preposterous to accept the stand that a person “against whom”, recovery certificate is issued, need not challenge the recovery certificate as such or for that matter, even if he has failed in the challenge to the recovery certificate (as in the present case), yet would be entitled to interdict the process of recovery of the amount specif i ed under the recovery certif i cate, by ostensibly challenging only the derivative action by way of Revision Application under section 154 of the Act without complying the mandatory requirement under sub-section (2A) thereof of 50% payment of the total amount of the recoverable dues. For, a person “against whom” recovery certif i cate has been duly issued and, who has not challenged the same or has failed in his challenge thereto, cannot be in a better position than a person who intends to challenge the recovery certif i cate itself by way of revision application under section 154 and who is then obliged to pay f i fty per cent, of amount of recoverable dues . In my opinion, having regard to the purpose and the legislative intent for introducing sub-section (2A), the language of that provision would deserve liberal construction so as to encompass challenge to the derivative actions, by way of revision application under section 154 of the Act , founded on the recovery certificate which has either not been challenged or the challenge thereto has failed. To put it differently, the rigours of sub-section (2A) would
