Bona fide title dispute permits deposit under section 269UG(3) instead of direct tender under section 269UG(1).

Where a bona fide dispute exists as to title or entitlement to receive consideration for property acquired under Chapter XX-C, the statutory mechanism permits deposit of the amount with the appropriate authority under section 269UG(3) instead of tendering it directly under section 269UG(1). The court's analysis treats a genuine doubt about ownership or entitlement as sufficient to attract section 269UG(3), including cases where documentary proof of joint ownership is absent. On the facts noted, the authority's finding of a title dispute meant its action was not without jurisdiction or illegal, and the writ challenge failed on merits.

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Issues: Whether the appropriate authority was justified in invoking section 269UG(3) of the Income-tax Act, 1961 instead of section 269UG(1), and whether any writ relief could be granted under Article 226 of the Constitution of India.

Analysis: The statutory scheme of Chapter XX-C requires tender of the consideration to the person entitled under section 269UG(1), but where there is a dispute as to title to receive the amount, section 269UG(3) permits deposit with the appropriate authority. A dispute in this context is not confined to rival claimants alone; a bona fide doubt regarding entitlement is sufficient to attract the subsection. On the facts recorded in the impugned order, the authority found a dispute regarding ownership and absence of clear documentary proof of joint ownership, and therefore treated the case as one involving a dispute as to title. In view of that finding, the authority's action could not be characterised as without jurisdiction or illegal.

Conclusion: Section 269UG(3) was held applicable and section 269UG(1) was held inapplicable. The challenge to the impugned order failed and no relief was granted in writ jurisdiction.

Final Conclusion: The orders under challenge were sustained and the writ petitions were rejected on merits.

Ratio Decidendi: Where there is a bona fide dispute as to title or entitlement to receive the consideration for property acquired under Chapter XX-C, the Central Government may deposit the amount with the appropriate authority under section 269UG(3) instead of tendering it under section 269UG(1).

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