(1) Where a person issues a certificate of deduction, collection or payment of tax at source without actual deduction, collection or payment to the credit of the Government, the person shall without prejudice to any other consequences to which he may be liable, be personally liable to pay the amount not being deducted, collected or paid to the credit of the Government.

(2) The Deputy Commissioner of Taxes shall take necessary action for the collection of amount mentioned in sub-section (1) from the person personally liable after giving the person a reasonable opportunity of being heard.