Chapter XX-C limits authority to purchase or issue no-objection certificate; private subdivision cannot justify rejection of a valid statement.

Chapter XX-C of the Income-tax Act gives the appropriate authority only a limited choice on a valid statement under section 269UC: it may either order pre-emptive purchase within the prescribed time under section 269UD(1), or, if no such order is made, issue a no-objection certificate under section 269UL(3). The authority cannot expand that scheme by rejecting the statement on the basis that privately sub-divided property is defective, unusable, or incapable of lawful enforcement, because the statute does not confer a broader discretion to test legality, utility, or marketability beyond its express terms. Strict construction applies, and private subdivision by itself did not justify refusal of relief under article 226.

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Issues: Whether the appropriate authority could reject the statement filed under Chapter XX-C of the Income-tax Act on the ground that the property had been privately sub-divided and that the transaction was defective or incapable of lawful use or enforcement, instead of either ordering purchase under section 269UD(1) or issuing a no-objection certificate under section 269UL(3).

Analysis: Chapter XX-C contemplates a limited statutory choice: where a valid statement is filed under section 269UC, the appropriate authority may either exercise the power of pre-emptive purchase within the prescribed time or, if no such order is made, issue the certificate of no objection. The authority was not empowered to enlarge that scheme by examining the legality, utility, or marketability of the privately divided property, or by treating the arrangement as defective merely because the parties had structured the transfer in a manner said to evade the object of the chapter. The provisions had to be construed strictly, and the court would not read into them a further discretion to reject the statement on grounds not found in the statute. The court also held that the petitioner's resort to a private subdivision did not, on the materials before it, justify refusal of relief under article 226.

Conclusion: The rejection of the statement was without jurisdiction, and the petitioner was entitled to the relief sought.

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