Chapter XX-C reporting threshold is tested by each owner's share, not the composite sale price.

Chapter XX-C of the Income-tax Act was held not to be triggered where separate owners transferred distinct shares and the value attributable to each vendor's share was below the statutory threshold. Although the proposed sale covered a composite property for a single consideration, the obligation to give notice under section 269UC depended on the consideration referable to each separate share on the facts found. On that basis, the clearance direction could not be sustained and the challenge failed.

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Issues: Whether Chapter XX-C of the Income-tax Act, 1961 applied to the proposed sale where the vendors separately owned contiguous plots but jointly held the building, and whether the obligation to give notice under section 269UC arose when the value attributable to each vendor's share was below Rs. 10 lakhs.

Analysis: The vendors were separate owners of distinct parcels of land and co-owners of the building erected over them. The proposed sale covered the entire property for a composite price of Rs. 12.75 lakhs, but the value of each vendor's share, on the facts found, was below the statutory threshold. On that factual footing, the statutory condition for notice under section 269UC was not attracted, and the direction requiring recourse to Chapter XX-C could not be sustained.

Conclusion: The requirement to communicate the agreement of sale under section 269UC was not attracted, and the challenge to the clearance direction failed.

Final Conclusion: The appeal was dismissed, and the view that Chapter XX-C did not apply on the facts was upheld.

Ratio Decidendi: For the purpose of Chapter XX-C, where separate owners transfer distinct shares and the consideration attributable to each share is below the statutory threshold, the reporting obligation under section 269UC is not triggered merely because the aggregate consideration for the composite transaction exceeds that threshold.

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