(1) Where a person issues a certificate of deduction, collection or payment of tax at source without actual deduction, collection or payment in favor of the Government, such person, without prejudice to all other consequences for which he may be liable, he shall be personally liable for the payment of any amount not deducted, collected or credited to the Government.

2) The Deputy Commissioner of Taxes shall take necessary steps to recover from him the amount payable under sub-section (1) after giving a reasonable opportunity of being heard to the personally liable person.