Court auction sales fall outside Chapter XX-C because the price is fixed through open bidding and court approval.

Chapter XX-C of the Income-tax Act does not apply to a court sale conducted by public auction, because the sale price is fixed through an open bidding process subject to court approval and the safeguards of Order XXI of the Code of Civil Procedure. In that setting, the undervaluation concern targeted by Chapter XX-C is absent, and the Income-tax authorities cannot override the price determined by the court process. The provision's object is therefore not related to disposal of property through court sale, and the view is consistent with earlier treatment of sales made under court-controlled pricing mechanisms.

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Issues: Whether Chapter XX-C of the Income-tax Act, 1961 applies to a court sale effected by public auction.

Analysis: A court sale by public auction is determined by the highest bid obtained in an open process, subject to court approval and the safeguards available under Order XXI of the Code of Civil Procedure, 1908. In such a sale, the concern of undervaluation that Chapter XX-C was designed to address does not arise. The authorities under the Income-tax Act cannot override the court's determination of the sale price, and the object of Chapter XX-C is not relatable to disposal of property by court sale. The view that the chapter is inapplicable to court sales was consistent with the prior treatment of sales made under court-determined prices pursuant to statutory protection provisions.

Conclusion: Chapter XX-C does not apply to court sales effected by public auction, and the challenge was rejected.

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