ORDER

1. The question that falls for consideration in this appeal by special leave against the judgment of the Madras High Court dated 21-6-1996 relates to the interpretation of the provisions of sub-section (4) of Section 269-UC of the Income Tax Act, 1961 (hereinafter referred to as the Income Tax Act). Section 269-UC is contained in Chapter XX-C relating to purchase by the Central Government of immovable properties in certain cases of transfer.

2. On 7-9-1995 the appellant entered into an agreement with the executors of Shri S. R. Unger for the purchase of urban property in the city of Madras (now Chennai) for a sum of Rs 5,50,00,000. The extent of the property is 23.5 grounds comprising 5239 sq mt of vacant land and 954 sq mt of built-up area. On the same date, i.e., 7-9-1995, an application in Form No. 37-I was filed before the appropriate authority, Madras. The appropriate authority addressed a letter dated 30-10-1995 to the intending transferors and transferees seeking certain clarifications in respect of nine points mentioned in the said letter. One of the said points was that the extent of the property under transfer is about 24 grounds which includes 8.01 grounds for whic