https://www.taxtmi.com/caselaws?id=12069 Presumptions under section 269C(2) of the Income-tax Act, 1961 apply only after initiation of acquisition proceedings by publication of notice in the Official Gazette under section 269D(1), and not at the pre-notice stage. The competent authority must first have material to satisfy the jurisdictional conditions under Chapter XX-A, including transfer of immovable property, understatement of apparent consideration by the requisite margin, and a reasonable belief that the understatement was made to evade tax or conceal income. An Inspector's report may have evidentiary value on market value, but it is insufficient by itself to show that extra consideration passed or that the apparent consideration was falsely stated with an evasive motive. On that basis, the acquisition proceedings were unsustainable for want of requisite material. en-us Tue, 30 Jul 2002 00:00:00 +0530 Tue, 16 Feb 2010 13:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12069 Presumptions under section 269C(2) of the Income-tax Act, 1961 apply only after initiation of acquisition proceedings by publication of notice in the Official Gazette under section 269D(1), and not at the pre-notice stage. The competent authority must first have material to satisfy the jurisdictional conditions under Chapter XX-A, including transfer of immovable property, understatement of apparent consideration by the requisite margin, and a reasonable belief that the understatement was made to evade tax or conceal income. An Inspector's report may have evidentiary value on market value, but it is insufficient by itself to show that extra consideration passed or that the apparent consideration was falsely stated with an evasive motive. On that basis, the acquisition proceedings were unsustainable for want of requisite material. Case-Laws Income Tax Tue, 30 Jul 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12069