JUDGMENT

D.P. Wadhwa, J.—This batch of 12 appeals is directed against the judgment dated December 1, 1998 of the Division Bench of the Delhi High Court interpreting Section 269UC of the Income Tax Act, 1961 (for short, the ‘Act’) and Rule 48L and Form 37-I of the Income Tax Rules, 1962 (for short, the ‘Rules’).

2. A number of writ petitions had been filed in the High Court by various parties challenging rejection of Form 37-I by the Appro­priate Authority. High Court by its impugned judgment allowed the petitions, set aside the orders of the appropriate authority and requiring it to take fresh decision in each of the cases in accordance with law and keeping in view the principles laid by the High Court in its judgment. Aggrieved Appropriate Authority has filed 11 appeals. M/s. DLF Universal Ltd. (for short, ‘DLF ) has also filed one appeal. It is aggrieved by that portion of the judgment of the High Court where the High Court said “no objec­tion by the Appropriate Authority based on an agreement for transfer of property which is to be constructed cannot be uti­lised for procuring a deed for transfer of that property which has been constructed.”

3. To understand the controversy between