Property acquisition under income-tax law sustained where factual evidence showed understatement of consideration and no question of law arose.

Under Chapter XX-A of the Income-tax Act, the acquisition notice was supported by definite material, including an earlier higher sale agreement, a later sale at a much lower apparent consideration, and an affidavit from the earlier proposed transferee. The presumptions in section 269C(2) were not the sole basis for initiation; the Tribunal also considered surrounding circumstances, oral evidence, valuation material, comparable sales and party conduct and concluded that the apparent consideration did not reflect the real transaction value. Challenges to valuation and understatement were treated as factual matters, and no question of law arose from the Tribunal's order. The acquisition order was upheld.

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Issues: Whether the acquisition of the property under Chapter XX-A of the Income-tax Act, 1961 was valid and whether any question of law arose from the Tribunal's order confirming the acquisition.

Analysis: The notice initiating acquisition was founded on definite material, namely the earlier agreement to sell at a higher price, the subsequent sale at a much lower apparent consideration, and the affidavit of the earlier proposed transferee. The presumptions in section 269C(2) were not treated as the sole basis for initiation. The Tribunal had examined the surrounding circumstances, oral evidence, valuation material, comparable sales and the conduct of the parties, and had found that the apparent consideration did not reflect the real transaction value. The challenge to valuation and to the inference of understatement of consideration raised issues of fact, not a question of law. The reliance on the decision concerning section 52(2) did not assist in the context of Chapter XX-A.

Conclusion: The acquisition order was upheld and the appeals failed because no question of law arose from the Tribunal's factual findings.

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