Court Rules Section 83 Can't Be Used Against Appellant Due to Separate Proceedings Against GM Powertech.

Provisional attachment - We are unable to accept the contention of the respondent that merely because proceedings were pending/concluded against another taxable entity, that is GM Powertech, the powers of Sections 83 could also be attracted against the appellant. This interpretation would be an expansion of a draconian power such as that contained in Section 83, which must necessarily be interpreted restrictively. - SC .....

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