( 1 ) THESE appeals are against an order of a Division Bench of the karnataka High Court confirming in turn the order of a Single Judge of that court allowing a writ petition filed by the respondents herein against an order passed by the appropriate authority under Section 269-UC (l) of the Income tax Act (for short "the Act") in exercise of the right to purchase a property under the provisions of the Act. The contention of the respondents before the high Court was that the vendors were co-owners and not joint owners and when for the purpose of Section 269-UC the property is valued, the value of the share of each co-owner should be considered in order to decide whether the transaction falls within the ambit of Section 269-UC. According to them, the total consideration is Rs 14 lakhs and the value of the share of each of them is much less than Rs 5 lakhs and the section is not attracted.

( 2 ) THAT contention was accepted by a Single Judge of the High Court who followed the judgment of the same Court in Appropriate Authority v. J. S. A. Raghava Reddy and allowed the writ petition. The Division Bench took the same view and followed the judgment in Raghava Reddy case.

( 3 ) IT is cont