S. Rajendra Babu, J.—These petitions are directed against two orders made under section 269UD(1) of the Income Tax Act, 1961 (for short, "the Act"), on July 25, 1989, initiating action under Chapter XX-C of the Act.

2. Respondents Nos. 2 and 3 entered into an agreement to sell their respective undivided interest in the property comprised in Municipal Nos. 4 and 5 (new Nos. 9 and 11), situate at Infantry Road, Bangalore, with the petitioner herein. The agreement entered into between the aforesaid parties disclosed that the consideration for sale of the property was Rs. 1,38,04,850 as far as the share of respondent No. 2 is concerned and Rs. 46,01,475 as far as the share of respondent No. 3 is concerned. The property in question consists of land measuring 43,309 square feet comprising within it main building and outhouse with a plinth area of 960 square meters. It is located, one side facing Queen's Road and the other side facing Infantry Road, Bangalore. This property originally belonged to one H. M. Maneckji, who purchased the same in a court sale on March 20, 1952, and the sale in his favour was confirmed on March 10, 1953. The said Maneckji, transferred the said property