Income Tax Act, 1961
Sch. II Part I Rule 9. GENERAL BAR TO JURISDICTION OF CIVIL COURTS, SAVE WHERE FRAUD ALLEGED.
Except as otherwise expressly provided in this Act, every question arising between the Tax Recovery Officer and the defaulter or their representatives, relating to the execution, discharge or satisfaction of a certificate, or relating to the confirmation or setting aside by an order under this Act of a sale held in execution of such certificate, shall be determined, not by suit, but by order of the Tax Recovery Officer before whom such question arises :
Provided that a suit may be brought in a civil court in respect of any such question upon the ground of fraud.