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e) Section 281 of the Income Tax Act does not create a charge. It is a negative declaration in the sense that certain transactions, viz., any charge or transfer made during the pendency of the proceeding and on completion thereof and before issuance of notice under Rule 2 of the Second Schedule are declared void to the extent of sums payable on completion of such proceeding.

f) The declaration of voidity under Section 281 of the Income Tax Act, is not absolute, but comes with exceptions, viz., that the charge/transfer though made during the pendency of proceedings under this Act or after completion but before issuance of notice, the charge/transfer, may still not be void if the same is made for adequate consideration and without notice of pendency of such proceedings or notice of such tax or sum being payable by the assessee or if the transfer is made with the previous permission of the Assessing Officer.