25. Levy to be a first charge

Any levy in default shall be a first charge on all the assets of the defaulter:

Provided that, –

such charge shall not extend to or affect any assets sold by such person to a bona fide purchaser for value, prior to the seizure of the same in accordance with the provisions of section 27;

as regards immovable property, the levy shall not rank in priority to any lease or encumbrance created bona fide for value and registered prior to the date of the seizure; or

as regards movable property, where the levy for the relevant quarters for more than five years is in default, the levy for relevant quarters within five years 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 of such levy.