Judgment

Arijit Pasayat, J.—Challenge in these appeals is to the judgment rendered by a Division Bench of the Karnataka High Court dismissing the Writ Petitions filed by the appellants.

2. The factual background in a nutshell is as follows :

The fourth Respondent and appellants entered into an agreement of sale dated 16.7.1987 in respect of premises bearing No. 377 R.M.V. Extension, Bangalore measuring 50 x 90. The total consideration was fixed at Rs. 18,00,000/-. Appellants paid a sum of Rs. 6,00,000/- by two cheques dated 16.7.1987 to the fourth respondent and the balance consideration was agreed to be paid at the time of registration of sale deed. The parties to the agreement were required under Chapter XX-C of the Income Tax Act, 1961 (in short the ‘Act’) read with Rule 48(L) of the Income Tax Rules, 1962 (in short the ‘Rules’) to file a Statement in Form No. 37-I before the appropriate authority specified under Chapter XX-C. Accordingly, appellants and fourth respondent filed Form No. 37-I along with certain documents on 29.10.1987. Thereafter, the appropriate authority passed an order dated 18.12.1987 purported to be under Section 269UD(1) of the Act, for pre-emptive purchase of