31. Any turnover tax in default shall be a first charge Turnover all the assets of the defaulter : Provided that
(i) such charge shall not extend to or affect any assets sold by the defaulter to a bona fide purchaser for value prior to the seizure of the same in accordance with the provisions of section 33 ; |
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(ii) as regards immovable property, the turnover tax shall not rank in priority to any lease or encumbrance created bona fide for value and registered prior to the date of such seizure; and |
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(iii) as regards movable property, where turnover tax for more than four quarters is in default, the tax for four quarters only, to be selected by the Commissioner-General, shall rank in priority to any lien or encumbrance created bona fide for value prior to the date of default. |
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