Income-tax attachment cannot extend to third-party plots in the same layout; registration must proceed for unaffected properties.

An attachment under Section 281-B of the Income-tax Act operates only against the assessee's identified property and cannot be extended to third-party plots merely because they form part of the same layout. The Andhra Pradesh High Court held that the attachment in question was confined to the assessee's own assets, so the Sub-Registrar had to identify only those plots covered by the income-tax order. Documents relating to plots owned by others were required to be received and processed in accordance with law if they otherwise met registration and stamp law requirements. The ruling protects third-party property from an overbroad tax attachment.

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Issues: Whether an attachment order under Section 281-B of the Income-tax Act, 1961, passed against the assets of one entity could be applied to plots owned by third parties, and whether the Sub-Registrar was bound to receive and process registration documents relating to such third-party plots.

Analysis: The attachment was found to be confined to the assets of SIMS, which alone were covered by the income-tax order. The Court held that where the lay out comprised plots owned by different persons, the attachment could not be extended to the petitioners' plots merely because they formed part of the same lay out. The Sub-Registrar was therefore required to identify the plots owned by SIMS and restrict the attachment only to those plots, while documents relating to other plots were to be received and processed in accordance with law if they otherwise satisfied the requirements of registration and stamp law.

Conclusion: The attachment under Section 281-B was limited to SIMS-owned plots and could not affect the petitioners' third-party plots; the Sub-Registrar was directed to process registration of such documents in accordance with law.

Final Conclusion: The petition was disposed of by protecting third-party property from a misconceived extension of the income-tax attachment and by requiring registration authorities to act only in respect of plots actually covered by the attachment.

Ratio Decidendi: An attachment under Section 281-B of the Income-tax Act, 1961 operates only against the assessee's identified property and cannot be extended to property of third parties merely because it is situated in the same layout.

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