K.A. Swami, Actg. C.J.

1. This appeal is preferred by the respondents in Writ Petition No. 13984 of 1992 (see above) against the order dated August 5, 1992, passed by the learned single judge.

2. The learned single judge has followed a decision of the High Court of Madras in K. V. Kishore v. Appropriate Authority .

The question for consideration is whether the provisions contained in section 269UC of Chapter XXC of the Income-tax Act, 1961, are applicable to the alienation of the property made under one deed by several co-owners, the value of which exceeds Rs. 10 lakhs but the value of the share of each of the co-owners does not exceed Rs. 10 lakhs.

3. The contention of learned counsel for the appellants is that, as the property is one and it is conveyed under one deed, even though it to owned by several persons, the provisions of Chapter XXC and specially section 269UC of the Income-tax Act are attracted. Section 269UC of the Act which is relevant for our purpose reads thus :

"269UC. (1) Notwithstanding anything contained in the Transfer of Property Act, 1882 (4 of 1882), or in any other law for the time being in force, no transfer of any immovable property of such value e