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The HC dismissed the petition challenging attachment by Respondent-3 (Tax Recovery Officer), upholding the impugned order. Applying s.281 and the Second Schedule provisions, the court held that any transfer of assets during pendency or after completion of assessment proceedings, before service of notice under Rule 2, is void against the Revenue; intention to defraud is not required under the amended statutory regime. The petitioner's purchase post-initiation of proceedings against Respondent-4 cannot be protected as a bona fide purchaser in summary Article 226 proceedings; factual determination requires a civil suit. Given the transfer occurred after notice and in the context of assessment, the HC found no reason to interfere with the writ court's conclusion.
The HC dismissed the petition challenging attachment by Respondent-3 (Tax Recovery Officer), upholding the impugned order. Applying s.281 and the Second Schedule provisions, the court held that any transfer of assets during pendency or after completion of assessment proceedings, before service of notice under Rule 2, is void against the Revenue; intention to defraud is not required under the amended statutory regime. The petitioner's purchase post-initiation of proceedings against Respondent-4 cannot be protected as a bona fide purchaser in summary Article 226 proceedings; factual determination requires a civil suit. Given the transfer occurred after notice and in the context of assessment, the HC found no reason to interfere with the writ court's conclusion.
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