HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Union of India and Anr. v. M/s. Chiranji Estate (P) Ltd. and Anr.
Civil Appeal No. 6053 of 1998
[2001] Supp. 1 SCR 366 ·
Income-tax Act, 1961: Chapter XX-C
Sources & disclosures includedDownload original judgment / order
2-judge bench · S. Rajendra Babu, J. · K. G. Balakrishnan, J.
Assessment years: Not specified; property agreement dated 28 August 1993
01 · Facts of the case
An agreement dated 28 August 1993 proposed sale of A-3, East of Kailash, New Delhi for Rs. 70 lakh. The Appropriate Authority compared it with E-326 in the same locality and ordered acquisition for alleged understatement. The sellers disputed comparability, pointing to location, plot size and building-value differences, and relied on another property, A-32. The Delhi High Court set aside the order. The Government appealed.
Source: SCR p. 367 / PDF p. 2
02 · Discussion by the Hon’ble Court
The Court noted that the show-cause notice used about Rs. 93,000 as the subject building's salvage value but the final order used about Rs. 9.92 lakh without disclosing the fact or basis of that increase to the parties. Two earlier valuation reports did not indicate undervaluation. The A-32 instance was rejected on irrelevant considerations. The Court found both comparing unsuitable properties and ignoring suitable comparables fallacious. These grounds sufficed to invalidate the authority's order.
Source: SCR pp. 367-368 / PDF pp. 2-3
03 · Judicial decision
The Court declined to interfere with the High Court and dismissed the Government's appeal without costs. Additional Department contentions identical to those in Civil Appeal Nos. 6050-6051 of 1998 were rejected for the reasons stated in that separate judgment; this short source does not repeat them.
Source: SCR p. 368 / PDF p. 3
04 · Outcome / in whose favour
In favour of the respondent property sellers: the High Court order setting aside the Appropriate Authority's acquisition remained effective. The Court upheld relief on deficiencies in the valuation process and comparisons, rather than fixing a substitute market price.
Source: SCR p. 368 / PDF p. 3
05 · AKHB REVIEW POINT
AKHB analysis: record why each proposed comparable is suitable or unsuitable, with adjustments for location, size and structures. Reconcile the notice valuation with the final calculation and identify material changes not disclosed for response. Obtain the companion judgment before relying on the additional arguments rejected only by reference.
Source: AKHB analysis based on SCR pp. 367-368 / PDF pp. 2-3
Source & verification
Download original judgment / order · Open cited source rendition
Three-page SCR scan; judgment begins on PDF page 2 and concludes on page 3. The reporter headnote on page 1 is distinguished from the judicial text.
- Full judicial text and operative relief read. Original bytes match the SHA-256 in the supplied source reconciliation.
Statutory scope
Apply the historical statutory text governing the decision. Current statutory applicability and Income-tax Act, 2025 equivalence have not been verified.
Later treatment
Source checked 2026-10-10. Full historical judgment checked. Comprehensive subsequent judicial treatment has not been verified; no current citator clearance is represented.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Coverage, AI disclosure & professional disclaimer
Selected Supreme Court income-tax decisions and procedural orders checked against their identified sources. This collection is not exhaustive. The research catalogue has 2,569 indexed PDF assets, including alternate copies and incidental matches; that is not a count of unique or reviewed judgments. Historical and unreported coverage remains open.
AI-assisted research checked against the identified source. Extraction, interpretation or omission errors remain possible. Source review does not mean independent approval by a practising professional. Verify every material statement against the complete original judgment.
General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on facts, assessment year, statutory version and jurisdiction. Subsequent treatment is unverified unless a note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.
The official 1961–2025 structural correspondence does not establish that a precedent applies under the new Act. Verify the enacted wording, commencement and transitional provisions separately.