TARUN CHATTERJEE, J.

( 1 ) WRIT petitioners Nos. 1 to 5 are the joint owners of the premises Nos. 9, 7/1a and 7/1b, Lovelock Place, Calcutta-700 009 (hereinafter referred to collectively as the said premises ). Writ petitioner No. 6 has entered into an agreement on January 28, 1994, with the writ petitioners Nos. 1 to 5 to develop the said premises. By the Finance Act, 1986, with effect from October 1, 1986, Chapter XX-C consisting of Sections 269u to 269uo was inserted in the Income-tax Act, 1961, with the object of inducing the transferors and the transferees to declare the full amount of consideration in their agreements for transfer. Section 269uc of the Income-tax Act, 1961 (hereinafter referred to as "the Act") provides as follows :" (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 exceeding ten lakh rupees as may be prescribed, shall be effected except after an agreement for transfer is entered into between the person who intends transferring the immovable property (hereinafter referred to as 'the transferor') and the person to whom i

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