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2016 (5) TMI 149 - MADRAS HIGH COURT

2016 (5) TMI 149 - MADRAS HIGH COURT - [2016] 381 ITR 79 - Restrictions on transfer of immovable property - benefit of scheme called "Kar Vivad Samadhan Scheme, 1998" - immunity certificate in favour of the vendor towards full and final settlement of tax arrears - Held that:- A reply was sent by the vendor as well as the purchasers stating that each of the sale deed was executed in respect of the one-sixth of undivided share of the property for a consideration of ₹ 9,00,000. When the prope .....

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e to be launched against the vendor and the purchasers. Therefore, it is very clear that the declaration, which has been filed by the vendor was in connection with and inclusive of the complaint complained in the show-cause notice, which emanated in the assessment proceedings, subsequent to the raid. When once the vendor submitted her application under the scheme and availed of the benefits thereof, including obtaining an immunity certificate, it also includes the violation which has been compla .....

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hether the immunity already granted to the vendor under the scheme was the subject matter of the complaint on its file or not. On such direction, the trial court rightly concluded that the immunity granted to the vendor covers the past transaction relating to the sale made by her which was the subject matter of the complaint before it. Further, this court once again directed the trial court by the order in the Criminal Original Petition once again directed the lower court to consider the petitio .....

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evision Case Nos. 967, 1553 and 1554 of 2004 - Dated:- 4-11-2015 - B. Rajendran, J. For the Petitioner : Ramasamy K. For the Respondent : R. Muthukumarasamy, Sandeep Bagmar, B. Kumar, S. Senthil, G. Saravana Kumar JUDGMENT V. Rajendran, J. 1. All these criminal revision cases are filed by the Income-tax Department aggrieved by the common order dated March 12, 2014 passed by the learned Additional Chief Metropolitan Magistrate, Egmore, Chennai. By the said order dated March 12, 2004, the petition .....

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e, Chennai 600 004 in favour of the respondents in Crl. R. C. Nos. 1553 and 1554 of 2004 (in short, the purchasers) by executing six sale deeds during March, 1995 in their favour thereby she transferred 1/6th of the undivided share of the aforesaid property for a sale price of ₹ 9,00,000 each having a total sale consideration of ₹ 54,00,000. It is claimed by the vendor that out of the sale price of ₹ 54,00,000, a sum of ₹ 44,00,000 has been remitted to the account of the .....

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was grossly under-valued as ₹ 54,00,000 to evade payment of tax. Therefore, on October 16, 1996, a show cause notice was issued by the Department under section 158BC of the Act calling upon the vendor to show cause as to why action should not be initiated under sec tion 276AB of the Act for contravening the provisions of section 269UC of the Act for the transactions effected by her for the assessment years 1987- 88 to 1996-97. Similar notices have been issued to the purchasers/respondents .....

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the appropriate authority could assume jurisdiction under the provisions of the Act. 2.2. Notwithstanding such explanation offered by the vendor as well as the purchasers, who are respondents herein, the Assistant Commissioner of Income-tax, Central Circle 11 (2), Chennai, has passed an order of assessment dated October 24, 1997 assessing the total undisclosed income at ₹ 96,38,355 and arrived at the tax due at 60 per cent. at ₹ 57,83,013. Aggrieved by the order of assessment dated O .....

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. Accordingly, on January 30, 1999, the vendor had opted for the said scheme and filed her declaration in form 1A before the Commissioner of Income-tax, Central Circle-II, Chennai. Such declaration filed by the vendor is in respect of the matters covered under the assessment period from April 1, 1986 to October 3, 1996 against which the statutory appeal was filed and pending before the Income-tax Appellate Tribunal. The designated authority under the scheme issued a certificate of intimation dat .....

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s. 2.3. Thereafter, on November 25, 1999, after eight months of issuance of the immunity certificate in favour of the vendor, the Department launched prosecution against the vendors as well as the purchasers by filing a complaint in E.O.C.C. No. 239 of 1999 for the offence punishable under sections 269UC and 276AB of the Act. According to the complainant/Department, the vendor as well as the purchasers have failed to file the statement in form 37-I in respect of the sale transaction effected bet .....

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ing to the vendor, the immunity certificate issued under the scheme was not taken into account by the Department and that the offence alleged against her is not made out by the Department especially when she has paid the entire tax arrears and later immunity certificate was given in respect of all matters. By an order dated February 23, 2001, this court disposed of W. P. No. 20364 of 1999 with a direction to the trial court to permit the vendor to make an application to drop the proceedings init .....

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ntending that section 269UC of the Act does not place any obligation on their part to obtain any clearance from any of the authorities of the Income-tax Department and they have nothing to do with the obligation to seek permission before purchasing the property in question. 2.6 A reply was filed by the Department contending, inter alia, that the petition filed by the vendor shall not be decided along with the petition filed by the purchasers as the Department would be left with no option to put .....

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14 directed the trial court to pass an order on the petition filed by the purchaser as well as the vendor within a period of three weeks, however, the main petitions in Crl. O. P. Nos. 6067 and 6068 of 2004 were kept pending. As directed by this court, arguments have been advanced by both sides and on March 12, 2004, the impugned orders were passed discharging the vendor as well as the purchasers from the purview of prosecution. As against the same, the present criminal revision cases are filed. .....

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ground that as against the order of discharge passed by the trial court, the present criminal revision cases are pending before this court and therefore, no relief could be granted. Accordingly, the criminal original petitions were dismissed as having become infructuous. 3.1. The learned senior special public prosecutor for Income-tax Cases, appearing for the petitioner mainly argued that the order dated February 23, 2001 passed by this court in W. P. No. 20364 of 1999 filed by the vendor, dire .....

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launched against the vendor and the purchasers is a separate proceeding inasmuch as the vendor as well as the purchasers have contravened the provisions contained in the Act and Rules. Even assuming without admit ting that the immunity certificate was granted to the vendor under the scheme, it has nothing to do with the violation committed by her in not filing the declaration under form 37-I of the Act. It is also not the case of the purchasers that this court issued any direction to them to fil .....

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all and the failure to file the declaration under form 37-I is an offence punishable under the provisions of the Act. Sections 276C, 276CC and 276CCC of the Act clearly indicate that there is a pre-emptive right on the part of the Central Government to take away the property of any assessee for non-filing of form 37-I of the Act. Therefore, as contemplated under section 269UC(3) of the Act, the person interested has to be taken note of. 3.2 The learned senior special public prosecutor would con .....

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honourable Supreme Court in the cases of (i) Jamnaprasad Kanhaiyalal v. CIT reported in [1981] 130 ITR 244 (SC) ; [1981] 3 SCC 441 and (ii) ITO v. Rattan Lal reported in [1984] 145 ITR 183 (SC) ; [1986] (Supp) SCC 370 to contend that the voluntary declaration of the tax due under a particular scheme or the immunity certificate obtained thereon will only confer to the declarant and not to the crediting firm or any other person. In such circumstance, the Department is justified in launching prose .....

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n summon cases. The power under section 258 of the Criminal Procedure Code to dis charge an accused at midway stage is restricted to those cases instituted otherwise than on complaints wherein no material witness was examined at all. Placing reliance on this decision, it is contended by the learned senior special public prosecutor that the prosecution has made out a prima facie case for proceeding against the accused by producing documentary evidence while so, the trial court is not justified in .....

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. Therefore, the learned senior special public prosecutor for the Department prayed for allowing the criminal revision cases. 4. On the contrary, the learned senior counsel appearing for the respondents in Crl. R. C. No. 1553 of 2004 and the first respondent in Crl. R. C. No. 1554 of 2004 would contend that the prosecution initiated against the purchasers is without authority of law and there is no jurisdiction to launch prosecution against the purchasers. Chapter XX-C and section 269U of the Ac .....

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ore it is in accordance with section 269UC of the Act which contemplates that if any immovable property is purchased having value exceeding ₹ 10 lakhs, then it should be disclosed by filing form 37-I of the Act before the appropriate authority. In any event, the vendor has availed of the benefits under the scheme and settled all the tax dues and obtained an immunity certificate. In such circumstances, the launch of prosecution against the purchasers is unnecessary. 5. The learned senior co .....

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se. 6. The learned senior counsel appearing for the sole respondent in Crl. R. C. No. 967 of 2004, who is the vendor, would contend that the vendor has availed of the benefit of the Scheme introduced by the Department. On the application of the vendor, under the scheme, the sum payable by her was determined and it has become conclusive with respect to the matters stated therein. The vendor also obtained an immunity certificate from the Department which duly covers the sale transaction made by he .....

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ate, the Department virtually foreclosed their right to further proceed against the vendor especially when the vendor paid the tax amount and availed of the benefits under the scheme during the pendency of statutory appeal filed by her before the Income-tax Appellate Tribunal. The immunity certificate issued in favour of the vendor duly protects her from launching of any prosecution by the Department for the relevant assessment year which is duly covered under the immunity certificate. Further, .....

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already intimated the sale of the property to the Department as per section 230A of the Act and obtained a no-objection certificate thereon. When the vendor availed of the benefits of the scheme, there is no bar for dropping all further proceedings against her as also against the purchasers. The trial court, in exercise of power conferred upon it, has rightly assessed the materials placed by the Department and rightly discharged the vendor. 7. In this context, reliance was placed on the decision .....

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or the vendor that there is no restriction either in the Transfer of Property Act or any other enactment to sell a portion of the property and to execute sale deeds thereof in favour of more number of persons. It is the desire and interest of the parties to enter into sale transaction to dispose of the entire building or a portion of the building and such sale will not in any manner be construed as an offence under any of the enactments. Under section 269UA(d) of the Act, immovable property is d .....

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me, Rules in form 3 that a sum of ₹ 31,88,675 has been paid by the vendor towards tax due which fell during the block assessment period April 1, 1986 to October 3, 1986. The relevant portion of the form of certificate for full and final settlement of tax arrears under section 90(2) read with section 81 of the Finance (No. 2) Act, 1998 in respect of the scheme issued to the vendor herein reads as follows : "And whereas, the designated authority, by order dated February 18, 1999 determi .....

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ned by the designated authority. And whereas the declarant had declared in the declaration made under section 88 that no writ petition or appeal or reference before any High Court or the Supreme Court against any order in respect of the tax arrears has been filed by such declarant. Now therefore in exercise of the powers conferred by sub-section (2) of section 90 read with section 91 of the Finance (No. 2) Act, 1998, the designated authority hereby issues this certificate to the said declarant ( .....

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he applicant." 10. It is clear from the above certificate issued under the scheme that such certificate was issued for the tax amount which fell due during the assessment year April 1, 1986 to October 3, 1996. In the present case, the prosecution came to be launched against the vendor and the purchasers in connection with the sale transaction took place during March, 1995 and it is duly covered by the certificate issued in favour of the vendor. As rightly pointed out, having received the ta .....

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rear as on the date of making the declaration under section 88, against which, a sum of ₹ 35,91,194 is indicated. In the declaration form, there is a separate column for "verification" which reads as under : "I, S. Ramayamma (name in block letters) son/daughter/of Shri Shambu Prasad, solemnly declare that to the best of my knowledge and belief (a) the information given in this declaration, statements and annexures accompanying it is correct and complete and amount of tax arr .....

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te of tax payable by the vendor has been duly mentioned. Further, the declaration states that it is referable to the previous years relevant to the assessment years indicated in this declaration. When the vendor has made such declaration and also made the tax arrears, the prosecution launched against her and the purchasers is unnecessary. Thus, what has been declared by the vendor in the declaration form is inclusive of the sale of the property during March, 1995 in favour of the purchasers. Thi .....

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sale deeds, including the alleged excess payment. 13. The learned senior counsel for the Department relied on the decision in the case of Appropriate Authority v. Smt. Varshaben Bharatbhai Shah reported in [2001] 248 ITR 342 (SC) ; [2001] 4 SCC 11, wherein the honourable Supreme Court had an occasion to consider that the transferors were co-owners and agreed to transfer their undivided share in the immovable property. In that context, it was held that what has to be seen for the purpose of attra .....

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y the honourable Supreme Court that the question of sale of share of individual rights does not arise and the sale consideration was to be taken as ₹ 47 lakhs. This decision will not lend support to the facts of this case. In this case, a raid was conducted in the residence of the vendor and the Department has assessed the total tax due. Against the assessment of tax, the vendor has filed an appeal. During the pendency of statutory appeal, the vendor has availed of the benefits of the sche .....

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especially in this case, a portion of the undivided property has alone be sold in favour of the vendors. 14. Before proceeding further, let us have a look into the provisions of sections 269UC and 278AB of the Act, which reads as follows : "269UC. Restrictions on transfer of immovable property.-(1) Not withstanding anything contained in the Transfer of Property Act, 1882 (4 of 1882) or in any other law for the time being in force, no transfer of any immovable property in such area and of su .....

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all be reduced to writing in the form of a statement by each of the parties to such transfer or by any of the parties to such transfer acting on behalf of himself and on behalf of the other parties. (3) Every statement referred to in sub-section (2) shall,- (i) be in the prescribed form ; (ii) set forth such particulars as may be prescribed ; and (iii) be verified in the prescribed manner, and shall be furnished to the appropriate authority in such manner and within such time as may be prescribe .....

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behalf, the appropriate authority may, in the discretion, allow and if the defect is not rectified within the said period of fifteen days or, as the case may be, the further period so allowed, then, notwithstanding anything contained in any other provision of this Chapter, the statement shall be deemed never to have been furnished." "As per rule 48K of the Income-tax Rules where the value of the sale deed exceeds ₹ 10 lakhs only, form 37-I has to be filed in so far as city of Mad .....

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r Commissioner under sub-section (1) shall not be made after institution of the prosecution proceedings after abatement. (3) The Principal Commissioner or Commissioner may, subject to such conditions as he may think fit to impose, grant to the person immunity from prosecution for any offence under this Act, if he is satisfied that the person has, after the abatement, co-operated with the Income-tax authority in the proceedings before him and has made a full and true disclosure of his income and .....

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ny conditions subject to which the immunity was granted and thereupon the pro visions of this Act shall apply as if such immunity had not been granted. (5) The immunity granted to a person under sub-section (3) may, at any time, be withdrawn by the Principal Commissioner or Commissioner, if he is satisfied that such person had, in the course of any proceedings, after abatement, conceded any particulars material to the assessment from the Income-tax authority or had given false evidence, and ther .....

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"any proceeding" under the Act should in the normal nomenclature also include any action to be taken for contravention of any of the provisions of the Act and Rules in respect of a transaction, in the present case, the alleged sale transaction. The further action as contemplated under section 269UC of the Act is non-filing of form 37-I of the Act which was originally started in the year 1996 itself by issuing a show-cause notice. A reply was also given by the respondents herein and sub .....

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tly sign with the vendor. The vendor has to submit form 37-I of the Act. What applies to the vendor will equally apply to the purchasers. When the vendor was issued with an immunity certificate in respect of the very same action itself, can the purchasers be made to suffer on the alleged non-filing of form 37-I, which according to the Department it is only a joint declaration. Further, in this case, as discussed earlier, the vendor has already obtained a no-objection certificate from the Departm .....

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upreme Court in the case of Appropriate Authority (IT Dept.) v. M. Arifulla [2002] 10 SCC 342 to contend that vendor is only a co-owner and the value of the each of the property sold by her has to be determined bearing in mind the provisions of section 269UC of the Act. 17. The learned senior counsel for the Department also relied on Killick Nixon Limited v. Deputy CIT [2002] 258 ITR 627 (SC) ; [2003] 1 SCC 145 to contend that immunity from prosecution cannot be restricted only for the offences .....

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her in E. O. C. C. No. 239 of 1999 and to direct the Department not to proceed against her in any manner by taking into account Form 3 issued in her favour under the Scheme. This court, by order dated February 23, 2001 directed the trial court to consider the request of the petitioner to drop the prosecution against her in the light of the immunity certificate issued in her favour. This court also directed the trial court to consider whether the immunity certificate granted to the vendor also c .....

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rosecution. 19. On the other hand, the Department has approached this court by filing Criminal Original Petition Nos. 6067 and 6068 of 2004 against the order passed by the trial court refusing to hear the application filed by the vendor and the purchaser separately. This court, by the order dated February 23, 2004 directed the trial court to pass orders on the petition filed by the vendor as well as the purchaser within three weeks and kept the criminal original petitions pending. Pursuant to su .....

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p the criminal prosecution against the vendor and purchasers and only thereafter, the lower court has passed the orders after a detailed analysis of the submissions made on both sides. In view of the order passed by the trial court, this court dismissed the Criminal Original Petition Nos. 6067 and 6068 of 2004 filed by the Department as infructuous. The Department again contended that the Criminal Original Petition Nos. 6067 and 6068 of 2004 should not have been dismissed and raised a plea befor .....

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herein and she has wantonly and wilfully sold the undivided share of the property by executing six sale deeds. In other words, a single transaction was split into six transactions only to ensure that there is no tax liability on the part of the vendor as well as the purchaser. Further, the vendor did not submit form 37-I and therefore, the launch of prosecution against the vendor as well as the purchasers is justifiable and in accordance with law. Such a contention of the learned senior special .....

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disclosed the value of the property covered therein at ₹ 9 lakhs and therefore it is also not barred or hit by the provisions of section 269UC of the Act which contemplates that if any immovable property is purchased having value exceeding ₹ 10 lakhs, then it should be disclosed by form 37-I of the Act before the appropriate authority. Therefore also, the contentions urged by the learned senior special public prosecutor for the Department cannot be sustained and it has to be rejecte .....

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at point of time, the Department did not object to the sale transaction. When intimation was given by the vendor, the buyer cannot be expected to obtain any clearance from the Income-tax Department, especially when the sale price covered under each of the sale deed is only ₹ 9 lakhs. Therefore, there is no obligation on the part of the buyers to either intimate the Department regarding the purchase or the value mentioned thereon. Further, the seller has obtained certificate under the then .....

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apparent sale consideration for transfer of the immovable property has to be disclosed. In the present case, the value of the property has been truly disclosed by the vendor in the application filed by her under the scheme mooted by the Department and it was also duly accepted and acknowledged by the Department by issuing a certificate thereof. The immunity certificate issued by the Department covers the sale transaction in question, which took place during March 1995. Therefore, the non-filing .....

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hem in case of violation of any of the Act and Rules. In the present case, unfortunately, the provisions of the Act which were alleged to have been violated by the vendor or purchasers have been repealed long back but it was not taken note of by the Department. Therefore also, at this stage, the action sought to be taken by the Department against the vendor and purchasers is unnecessary. 24. It is seen from the orders passed by the trial court that it has taken note of the entire documentary evi .....

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ndor was relieved. The trial court, on appreciation of para 10 of the complaint concluded that the total sale consideration received by the vendor is only ₹ 54 lakhs and the whole property is sold to the purchasers by executing six separate sale deeds and not for ₹ 1,30,00,000 as averred by the Department. Therefore, the trial court concluded that even assuming the property was sold for more value, the obligation on the part of the vendor and purchasers to file form 37-I arises only .....

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erials placed on record and reasons were given by the trial court thereof. 25. Further, it is important to note that the offence complained of against the vendor and the purchasers is a compoundable offence. The argument of the Department is that the present charge relates to non-filing of form 37-I of the Act and it is totally different from the tax due. The filing of the declaration and the consequential payment of tax due will not enure to the benefit of the accused to get discharged from the .....

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7-I will arise only if the sale transaction is more than ₹ 10 lakhs. In the present case, as mentioned supra, each of the sale deed has been executed for a value of ₹ 9 lakhs besides that the vendor has intimated the Income-tax Department prior to alienating the property in favour of the purchasers. While so, I hold that non-filing of form 37-I by the vendor, in the present facts and circumstances, will not enure to the benefit of the Department to launch prosecution against the vend .....

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ty at ₹ 1,30,00,000 which the vendor sold for ₹ 54,00,000 in favour of the purchasers. Further, at this juncture, it is very pertinent to note that the Department issued a show-cause notice on October 16, 1996 itself under section 158BC of the Act to the vendor. In that notice, specifically the vendor was called upon to explain as to why action should not be initiated against her under section 276AB of the Act for contravening the provisions of section 269UC of the Act for the transa .....

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the purchasers stating that each of the sale deed was executed in respect of the one-sixth of undivided share of the property for a consideration of ₹ 9,00,000. When the property purchased under each of the sale deed is ₹ 9 lakhs and it is less than ₹ 10 lakhs, they are not having any legal obligation to submit form 37-I of the Act. Conveniently, the Department has not taken any action on the basis of the reply submitted by the vendor as well as the purchasers to the show-caus .....

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