https://www.taxtmi.com/caselaws?id=71804 Chapter XX-A acquisition proceedings were held invalid because the Gazette publication under the first proviso to section 269D(1) was made after the mandatory nine-month period, so initiation was time-barred. The Competent Authority also lacked jurisdiction under section 269C(1) because, at the stage of initiation, independent material was required to show understatement of consideration with the object of tax evasion or concealment; an estimated excess of fair market value over apparent consideration was insufficient. On the evidence, the comparable sales relied upon were dissimilar, the valuation adopted was not sustained, and the statutory presumption under section 269C(2) stood rebutted. en-us Mon, 24 Feb 1992 00:00:00 +0530 Wed, 27 Apr 2011 11:44:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71804 Chapter XX-A acquisition proceedings were held invalid because the Gazette publication under the first proviso to section 269D(1) was made after the mandatory nine-month period, so initiation was time-barred. The Competent Authority also lacked jurisdiction under section 269C(1) because, at the stage of initiation, independent material was required to show understatement of consideration with the object of tax evasion or concealment; an estimated excess of fair market value over apparent consideration was insufficient. On the evidence, the comparable sales relied upon were dissimilar, the valuation adopted was not sustained, and the statutory presumption under section 269C(2) stood rebutted. Case-Laws Income Tax Mon, 24 Feb 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71804