HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE

Krishna Kumar Rawat and others v. Union of India and others

Civil Appeal Nos. 9800-9801 of 2010 with Civil Appeal No. 9901 of 2010
[2019] 10 SCR 333 ·
Income-tax Act, 1961: sections 269UC, 269UD(1), 269UD(1A), 269UE(1) and 269UG(4)

Holding and result. The pre-emptive purchase under section 269UD was upheld because the valuation findings were evidence-based and met the statutory test. The buyers’ appeals failed; the Union appeal was partly allowed because disbursement had to be left to the appropriate authority under section 269UG(4).

Reasoned final decisionRevenue on validity of purchase; mixed on disbursement directions.

Two-judge bench; judgment delivered by Abhay Manohar Sapre, J. · Abhay Manohar Sapre, J. · Dinesh Maheshwari, J.

01 · Facts of the case

Prospective buyers agreed to buy land and godowns in Jaipur for Rs.99,84,500 and filed Form 37-I. The appropriate authority found that fair market value exceeded the apparent consideration by at least 15 percent and ordered pre-emptive purchase under Chapter XX-C. The High Court upheld the purchase but issued directions concerning the fixed-deposit consideration.

Source: Primary judgment: facts and procedural setting

02 · Discussion by the Hon’ble Court

The Court confined review of the valuation decision to legality, relevant material, natural justice, statutory compliance and perversity. The authority had laid a factual foundation in its notice, considered objections and recorded a valuation finding consistent with section 269UD and C.B. Gautam. Separately, section 269UG(4) required the appropriate authority—not the High Court—to decide disbursement of the purchase consideration.

Source: Primary judgment: reasoning

03 · Judicial decision

The valuation findings were neither arbitrary, illegal nor perverse and the section 269UD purchase stood. The High Court’s disbursement directions were replaced by a direction to the appropriate authority to deal with the amount under section 269UG(4).

Source: Primary judgment: holdings

04 · Outcome / in whose favour

Civil Appeal Nos. 9800-9801 of 2010 were dismissed. Civil Appeal No. 9901 of 2010 was partly allowed to the limited extent of leaving disbursement to the appropriate authority.

Source: Primary judgment: operative disposition

05 · AKHB REVIEW POINT

AKHB analysis: in a historical Chapter XX-C file, separate the validity of the pre-emptive purchase from the statutory handling of consideration. Preserve the show-cause valuation basis, objections and authority findings; do not treat the High Court as the disbursement authority where section 269UG(4) applies.

Source: Primary judgment: review-point basis

Source & verification

Download original judgment / order · Open cited source rendition

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Statutory scope

Historical statutory provisions are described as they appeared in the report. Verify the current enactment, amendments and later judicial treatment before reliance.

Later treatment

Source checked 2026-10-12. No comprehensive later-treatment or present-law clearance is represented. The note reports the historical statutory text and result in this primary report only.

Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.

AI disclosure & professional disclaimer

This AKHB research note was prepared with AI assistance from the identified primary report and has not been represented as independently human-reviewed.

General legal and tax research only; not legal or tax advice. Verify the complete judgment, governing statutory version and subsequent judicial treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court's holding, and no current-law clearance is claimed.

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