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Section 281 deem certain transfers of assets void if they are transacted during the pendency of any proceeding under this Act by way of sale, mortgage, gift, exchange etc. in favour of any other person viz a viz.; against any liability arising as a result of the completion of the said proceeding to protect interest of revenue who enjoys priority over claims of other creditors.
The pendency could be on account of either of the following:-
A. Any failure to file the returns required under section 139(1) or to file a revised return under section 139(4) or 139(5);
B. Any failure to comply with the notices issued under section 142(1);
C. Any failure to completelay with notice under section143(2);
D. Any failure to comply with the directions issued under section 142(2A) etc.
In the case reported at [2021] 435 ITR 713 (Mad)the purchaser got trapped in a transaction of purchase of a plot after receiving an attachment order from TRO much after the date of purchase by him consequent to an order passed on assessment later to the date of transaction .
The petitioner sorrowfullyapproached the Income-tax Officer, the Tax Recovery Officer and the Income-tax Ombudsman and PCIT for lifting the attachment of the purchased property for more than five long years.
The High Court even declined to grant any relief five year later and remanded the subject to the TRO to decide the case of the petitioner whether it fell within the proviso to section 281 who being the competent authority under rule 11 of the Second Schedule to the Act to pass an appropriate order upon investigation.

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