Finality of compulsory purchase orders bars civil suits that indirectly seek to set aside Income-tax proceedings.

A civil suit challenging a compulsory purchase order under Chapter XXC was treated as barred because its substantive reliefs would require the court to nullify the order under Section 269UD(1) and the connected proceedings. Sections 269UN and 293 of the Income-tax Act were read as giving finality to orders made under Section 269UD(1) and as barring suits that seek to set aside or modify proceedings or orders under the Act. On that basis, the court held that indirect challenges cannot be used to achieve what is directly prohibited, and the civil court lacked jurisdiction under Section 9 CPC.

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Issues: (i) Whether the suit was barred by Sections 269UN and 293 of the Income-tax Act, 1961, and therefore outside the civil court's jurisdiction under Section 9 of the Code of Civil Procedure, 1908.

Issue (i): Whether the suit was barred by Sections 269UN and 293 of the Income-tax Act, 1961, and therefore outside the civil court's jurisdiction under Section 9 of the Code of Civil Procedure, 1908.

Analysis: The reliefs sought in the plaint were examined in substance and not merely in form. The declaration that the compulsory purchase order had abrogated, and the consequential reliefs of revesting and possession, would directly or indirectly require the court to nullify the order passed under Section 269UD(1) and the proceedings under Chapter XXC. Section 269UN gives finality to orders under Section 269UD(1) and bars them from being called in question in any proceeding under the Act or any other law. Section 293 further bars suits that seek to set aside or modify any proceeding taken or order made under the Act. The court held that a civil suit cannot be used to achieve indirectly what cannot be done directly.

Conclusion: The suit was barred and the civil court had no jurisdiction to entertain it.

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