Implied exclusion of civil jurisdiction under a self-contained tax acquisition scheme barred the civil suit challenging the proceedings.

Chapter XXA of the Income-tax Act was treated as a complete self-contained scheme for acquisition of immovable property allegedly transferred below fair market value, with notice, objections, enquiry, a reasoned order and statutory appeals. Because the Act provided a special forum and adequate remedies for determining the validity of the transfer and the acquisition proceedings, civil court jurisdiction was impliedly excluded even though section 293 then contained no express bar. A plea that the transfer was sham did not preserve civil jurisdiction, as that issue also fell within the statutory mechanism. The civil suit was therefore not maintainable.

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Issues: Whether the civil court's jurisdiction was impliedly barred in a suit challenging acquisition proceedings initiated under Chapter XXA of the Income-tax Act.

Analysis: Chapter XXA created a complete statutory scheme for acquisition of immovable property alleged to have been transferred for less than fair market value. The scheme provided for notice, objections by the transferor and transferee, enquiry, a reasoned order by the competent authority, appeal to the Appellate Tribunal, and a further appeal on a question of law. Although section 293 of the Income-tax Act, as it then stood, did not expressly bar a civil suit against an order under Chapter XXA, the statutory remedy was held to be self-contained and adequate. Applying the principles on exclusion of civil jurisdiction, the existence of a special liability, the determination of that liability by a special tribunal, and the availability of remedies within the Act showed that civil jurisdiction was necessarily excluded. The plea that the alleged transfer was a sham and therefore raised a collateral fact was rejected, as the Act itself provided the forum for deciding the validity of the transfer and the acquisition proceedings.

Conclusion: The civil court had no jurisdiction to entertain the suit, and the bar of jurisdiction operated by implication.

Final Conclusion: The challenge to the acquisition proceedings could not be pursued in a civil suit because the Income-tax Act furnished the exclusive statutory remedy and the dismissal of the suit was upheld.

Ratio Decidendi: Where a statute creates a special liability, provides a complete mechanism for determining that liability, and confers finality subject to statutory appeals, the jurisdiction of the civil court is impliedly excluded even without an express bar.

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