Section 415
Section 415: stay, amendment or cancellation of a recovery certificate
Section 415 gives the Tax Recovery Officer power to pause recovery by granting time to pay, and requires the recovery certificate to be adjusted if the underlying tax demand is later reduced through an appeal or other proceeding.
This explanation is AI-assisted and pending review by our CA/CS team. It is general information, not professional advice - always cross-check against the bare law text above or talk to our tax team for guidance specific to your situation.
Granting time to pay and staying recovery - Section 415(1)
"The Tax Recovery Officer may grant time for the payment of any tax and, till the expiry of such time, shall stay the recovery proceedings for such tax."
Effect of a later reduction in the demand - Section 415(2)
Where a certificate has been drawn up and the outstanding demand is subsequently reduced as a result of the underlying order being modified in an appeal or other proceeding, the Tax Recovery Officer must:
- If the order is still the subject of further proceedings under the Act, stay recovery of the part of the certified amount that corresponds to the reduction, for as long as the appeal or proceeding remains pending
- If the order that was under appeal or other proceeding has become final and conclusive, amend the certificate, or cancel it
Frequently asked questions
Can the Tax Recovery Officer pause recovery proceedings?
Yes - Section 415(1) lets the Tax Recovery Officer grant time for payment, and requires him to stay recovery proceedings for that tax until the granted time expires.
What happens to a recovery certificate if the tax demand is reduced on appeal?
If the reducing order is still under further appeal or proceeding, the corresponding part of the certified recovery amount is stayed while that appeal is pending. If the reducing order has become final, the certificate is amended or cancelled.
Related sections
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Get help staying or amending a tax recovery certificateLast updated 9 September 2026