Chapter XX-C jurisdiction limits prevent scrutiny of title or contract validity; no objection certificate must issue after the purchase period lapses.

Chapter XX-C of the Income-tax Act confines the appropriate authority to deciding whether the Central Government should pre-emptively purchase the property on undervaluation grounds or, failing that within the prescribed time, issue a no objection certificate. The authority cannot refuse to act on Form No. 37-I by examining the validity of the proposed agreement, the transferor's title, or other collateral impediments to transfer, as those matters fall outside its jurisdiction. Once the period for passing a purchase order expires, no further purchase order can be made, and the certificate must issue. A refusal based on alleged defects in title or agreement is therefore without jurisdiction.

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Issues: Whether the appropriate authority under Chapter XX-C of the Income-tax Act, 1961 could refuse to act on a statement in Form No. 37-I and decline a no objection certificate on the ground that the proposed sale was invalid or that the transferor's title was defective, and whether it was bound to issue the certificate once it chose not to exercise the pre-emptive right of purchase within the stipulated time.

Analysis: The statutory scheme of Chapter XX-C confines the appropriate authority to considering whether the property should be purchased by the Central Government on the ground of undervaluation, or whether a no objection certificate should be issued if no purchase order is made within the prescribed period. The authority has no jurisdiction to adjudicate on the legality of the proposed agreement, the validity of the transferor's title, or other collateral impediments to transfer; such questions are for other forums. Once the time for passing a purchase order expired, no further purchase order could be made, and the statement in Form No. 37-I could not be treated as infructuous merely because the authority believed the transfer required prior clearance from another office.

Conclusion: The refusal to issue the no objection certificate on grounds touching the validity of the agreement and title was without jurisdiction, and the petitioner was entitled to issuance of the certificate.

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