Tax-evasion object must be supported by material before acquisition proceedings can validly begin under Chapter XX-A.

Proceedings for acquisition of immovable property under Chapter XX-A could be initiated only if the statutory conditions in section 269C were supported by material showing both understatement of the apparent consideration and a tax-evasion object. A mere comparison with a single sale instance or a tentative market-rate estimate did not meet that jurisdictional threshold, because it did not connect the transfer price to any design to reduce or evade tax. On the facts noted, the record showed only a valuation comparison, not the essential material required by law, so the initiation was treated as without jurisdiction and the challenge succeeded.

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Issues: Whether initiation of proceedings for acquisition of immovable property under Chapter XX-A was without jurisdiction for want of material to show that the apparent consideration was not the true consideration and that the understatement was with the object of evading tax.

Analysis: Chapter XX-A of the Income-tax Act, 1961 permits acquisition proceedings only when the statutory conditions in section 269C are satisfied. The competent authority relied on a single sale instance and a tentative market-rate estimate, but the record did not disclose material connecting the transfer price with any design to facilitate reduction or evasion of tax. The note prepared by the authority showed, at most, a comparison of values, without supporting material on the essential jurisdictional requirement that the consideration was understated with the requisite tax-avoidance object.

Conclusion: The initiation of proceedings was without jurisdiction and the challenge succeeded.

Ratio Decidendi: Proceedings under section 269C can be initiated only on the basis of material satisfying all jurisdictional conditions, including material showing that the stated consideration is not true and is understated with the object of tax evasion; a bare valuation comparison is insufficient.

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