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Issues: Whether the Special Court under the Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992 could examine the bona fides, reasonableness, justification, or enforceability of tax liability claims raised by the Income-tax Department while directing distribution of attached property.
Analysis: Section 11 of the Act empowers the Special Court to issue directions to the custodian for disposal of attached property and to ensure that specified liabilities, including taxes, are paid in the order of priority prescribed by the statute. The Court held that this power is confined to determining priorities and the extent to which a claim can be satisfied from available funds. It does not authorise the Special Court to sit in appeal over assessments made by the competent tax authority, the Tribunal, or a court acting under the taxing statute. The reference to the earlier liquidation decision did not enlarge the Special Court's powers, because that decision only recognised the winding-up court's role in protecting competing creditors after tax had already been determined.
Conclusion: The Special Court had no jurisdiction to test whether the tax assessments or claims were bona fide, reasonable, justified, or enforceable, and its order permitting such an inquiry was unsustainable.