JUDGMENT

Ruma Pal, J.-The appellants challenge under Article 226 to the order passed by the Appropriate Authorities under Section 239 UD (1) of the Income Tax Act, 1961 (referred to hereafter as the Act ) was turned down by the Andhra Pradesh High Court. They have therefore assailed the decision of the High Court before us.

2. The property which was the subject matter of the order under Section 269UD(1) was part of premises situated at Road No. 3, Banjara Hills, Hyderabad. The entire premises covered an area of about 7100 sq. mts and was jointly owned by one Leila D. Lean and her two sisters. On 13th March 1988, the three owners agreed to sell the entire premises to the appellants. Before the conveyance could be executed, Leila Lean died. The executor named in her will, through a general Power of Attorney Holder, one Sri Armugham, entered into a fresh agreement with the appellants on 27th April 1989 agreeing to sell Leila Lean s 1/3 undivided share in the property. The two other sisters appointed the appellants as their power of attorney holders. In their capacity as the power of attorney holders the appellants sold demarcated portions of the property to nominees of the appellants