HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Ramesh Bhai J. Patel etc. v. Union of India
Civil Appeal Nos. 1158-1160 of 1998
[2000] Supp. 5 SCR 424 ·
Income-tax Act, 1961: sections 269UA(b), 269UG and 269UH; Chapter XX-C
Sources & disclosures includedDownload original judgment / order
3-judge bench · S. P. Bharucha, J. · N. Santosh Hegde, J. · Y. K. Sabharwal, J.
Assessment years: Not specified; property-transfer valuation dispute
01 · Facts of the case
The assessees appealed from the Gujarat High Court's dismissal of their writ petitions concerning section 269UA(b). They argued that discounting should run only from the Central Government's payment date to the contractual last payment date, because early Government payment compensated the transferor. A broader contention that there could be no discount was not argued. Detailed agreement amounts and dates are not stated in this judgment.
Source: SCR pp. 425-426 / PDF pp. 2-3
02 · Discussion by the Hon’ble Court
The Court read apparent consideration as a valuation of the contractual consideration on the agreement date. Where payment is deferred beyond that date, the statutory discount removes the assumed interest element for the interval until the contractual payment date or dates. This calculation is not linked to when the Government pays after compulsory purchase. The separate payment and revesting provisions in sections 269UG and 269UH do not change that valuation date. The Court rejected the contrary Bombay High Court interpretation in Shrichand Raheja.
Source: SCR pp. 426-428 / PDF pp. 3-5
03 · Judicial decision
All three appeals were dismissed with costs. The Court held that the discount period begins on the agreement date and runs to the contractual date or dates for payment of deferred consideration.
Source: SCR pp. 427-428 / PDF pp. 4-5
04 · Outcome / in whose favour
In favour of the Revenue on the method of calculating apparent consideration under section 269UA(b). The assessees' proposed commencement date based on Government payment was rejected. No individual substitute purchase price was calculated in the Supreme Court judgment.
Source: SCR p. 428 / PDF p. 5
05 · AKHB REVIEW POINT
AKHB analysis: build a date-wise contractual payment schedule before computing historical apparent consideration. Keep that discounting exercise separate from statutory deadlines for the Government to tender purchase consideration. Do not cite the rejected Bombay interpretation as an operative rule, or extrapolate the historical prescribed rate to a different valuation provision.
Source: AKHB analysis based on SCR pp. 426-428 / PDF pp. 3-5
Source & verification
Download original judgment / order · Open cited source rendition
Five-page SCR scan; judgment starts on PDF page 2 and concludes on page 5. The statutory discount-period issue is determined without detailed individual transfer facts.
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