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of HC dismissed the appellants' writ appeals and upheld the rights of anonymous purchasers as bona fide purchasers for value without notice. The Court held that the proviso to Section 24-A/43 protects transfers made for adequate consideration absent notice of pending tax proceedings or demand; clause (ii) (prior permission) was inapplicable. The Revenue failed to plead or adduce material establishing collusion, fraud or intent to defraud, a jurisdictional fact necessary to invoke Sections 24-A/43. Encumbrance certificates showed no antecedent charge in most cases and, where a charge existed, it post-dated the sales. Consequently the purchasers' titles could not be encumbered by the tax demands and the appeals were dismissed.
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