https://www.taxtmi.com/caselaws?id=37785 Protection for a transferee for valuable consideration without notice under the proviso to section 281 of the Income-tax Act cannot be read into rule 16 of the Second Schedule. Section 281 targets transfers made to defeat the revenue during pending proceedings, while rule 16 governs private alienations after service of notice and attachment in recovery proceedings. Because the two provisions operate in distinct statutory fields and address different mischiefs, the section 281 proviso cannot be imported by implication into rule 16. A bona fide transfer for value therefore cannot defeat an attachment made under the recovery schedule. en-us Mon, 18 Dec 1978 00:00:00 +0530 Thu, 01 Apr 2010 11:15:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37785 Protection for a transferee for valuable consideration without notice under the proviso to section 281 of the Income-tax Act cannot be read into rule 16 of the Second Schedule. Section 281 targets transfers made to defeat the revenue during pending proceedings, while rule 16 governs private alienations after service of notice and attachment in recovery proceedings. Because the two provisions operate in distinct statutory fields and address different mischiefs, the section 281 proviso cannot be imported by implication into rule 16. A bona fide transfer for value therefore cannot defeat an attachment made under the recovery schedule. Case-Laws Income Tax Mon, 18 Dec 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37785