Jurisdiction for acquisition notices requires clear independent belief on understatement and tax evasion, not presumptions alone.

Jurisdiction to initiate acquisition proceedings under Chapter XXA depends on a prior independent "reason to believe" under section 269C(1) that the apparent consideration was materially understated and that the understatement was for tax evasion or concealment. The presumptions in section 269C(2) operate only after valid jurisdiction is assumed and cannot themselves supply the basis for issuing notice under section 269D(1). A notice reflecting uncertainty about the statutory object, including use of "and/or", indicates non-application of mind and failure to satisfy the jurisdictional conditions.

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Issues: Whether the Competent Authority could validly assume jurisdiction to initiate acquisition proceedings under Chapter XXA on the basis of the notice under section 269D(1), when the requisite belief under section 269C(1) was not independently formed on the material available and the notice itself reflected uncertainty as to the object of understatement.

Analysis: The jurisdiction to initiate proceedings depended on satisfaction of the conditions in section 269C(1), including a reason to believe that the apparent consideration was materially understated and that the understatement was with the object of facilitating tax evasion or concealment. The presumptions in section 269C(2) could operate only after valid assumption of jurisdiction and could not supply the basis for assuming jurisdiction. On the facts, the consideration recorded in the sale deed was not shown to be unreal, the transaction represented the aggregate of earlier purchase prices paid by the purchasers and the retained portions of the vendors, and the notice itself used the expression "and/or" between the two statutory objects, indicating uncertainty and absence of a clear, focused belief. That amounted to non-application of mind and failure to satisfy the third statutory condition.

Conclusion: The notice and the assumed acquisition jurisdiction were invalid; the condition precedent under section 269C(1) was not satisfied, and the challenge succeeded.

Ratio Decidendi: Presumptions under section 269C(2) cannot be used to found jurisdiction under section 269C/269D, and a valid notice requires a clear, independently formed belief on all jurisdictional conditions, including the specific statutory object of understatement.

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