82. Tax to be first charge on property.—

Notwithstanding anything to the contrary contained in any law for the
time being in force, save as otherwise provided in the Insolvency and Bankruptcy Code, 2016, any amount payable
by a taxable person or any other person on account of tax, interest or penalty which he is liable to pay to the
Government shall be a first charge on the property of such taxable person or such person.