https://www.taxtmi.com/caselaws?id=19347 Section 281 of the Income-tax Act is declaratory and does not confer independent adjudicatory power on income-tax authorities to declare a transfer void. In the absence of any prescribed statutory procedure, enforcement of the Revenue's claim had to be pursued through properly constituted civil proceedings, not by an internal tax order. The court also held that an order made against a deceased assessee could not survive. Because the section 281 declaration was unsustainable, the consequential attachment notice under section 226(3) also failed: that provision applies only where money is due or may become due to the assessee or is held on the assessee's account, which could not be established on the invalid premise relied on by the Revenue. en-us Mon, 17 Jan 1994 00:00:00 +0530 Thu, 05 Nov 2009 16:07:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=19347 Section 281 of the Income-tax Act is declaratory and does not confer independent adjudicatory power on income-tax authorities to declare a transfer void. In the absence of any prescribed statutory procedure, enforcement of the Revenue's claim had to be pursued through properly constituted civil proceedings, not by an internal tax order. The court also held that an order made against a deceased assessee could not survive. Because the section 281 declaration was unsustainable, the consequential attachment notice under section 226(3) also failed: that provision applies only where money is due or may become due to the assessee or is held on the assessee's account, which could not be established on the invalid premise relied on by the Revenue. Case-Laws Income Tax Mon, 17 Jan 1994 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=19347