Section 281 does not give final adjudicatory power to the tax officer; it is only a recovery aid, not a binding rights determination.

Section 281 of the Income-tax Act is a substantive declaration of law, in pari materia with section 53 of the Transfer of Property Act, and not a complete adjudicatory code. The Income-tax Officer's expression of opinion or intention under that provision is only a preliminary step in aid of tax recovery; it does not finally declare a transfer void against the Revenue or conclusively determine title, fraud, or the parties' substantive rights. A civil suit and the ordinary recovery process remain available, so the provision does not vest exclusive or final deciding power in the Income-tax Officer.

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Issues: Whether section 281 of the Income-tax Act confers adjudicatory jurisdiction on the Income-tax Officer to finally declare a transfer void as against the Revenue, and whether an order or expression of intention under that provision affects the parties' substantive rights.

Analysis: Section 281 was treated as a substantive declaration of law, in pari materia with section 53 of the Transfer of Property Act, rather than as a complete adjudicatory code. The expression of an opinion or intention by the Income-tax Officer under that provision was held to be only a preliminary step for recovery of tax and not a conclusive determination of title or fraud. The adjudicatory process under the recovery machinery and the remedy of a civil suit remained available to the claimant, so the provision did not confer an exclusive or final deciding power on the Income-tax Officer.

Conclusion: Section 281 does not confer final adjudicatory jurisdiction on the Income-tax Officer, and an order made under it is only a step in aid of recovery, not a binding determination of the parties' substantive rights.

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