These three appeals are combined together as they relate to acquisition of property held in common by three appellants. property is situated at 138, Race Course Road. Amritsar. appellants have raised common contentions and, therefore, we dispose of these appeals by consolidated order. Facts which relate to this appeal are that partly built house property sitate at 138, Race Course Road, Amritsar was held by four transferrors Shri Ashok Nayyar, Shri Surinder Kumar, Shri Sham Sunder and Shri Ravinder Nayyar, all sons of Shri Chunni Lal near Sirki Banda, Amritsar. Every one of them held 1/4 share in property. property consisted of plot measuring 1827 sq. yds. building was single storeyed and was only half built. When Assistant Valuation Officer visited property for inspecting it, he found construction of property was in progress. This supported fact mentioned in registered deed that property at 138, Race Course Road was only half finished or partly built property. Each transferror transferred his 1/4th share held by him by separate deed to three transferees, Shri Subash Vohra, Shri Kuljeet Vohra and Smt. Sumitra Devi all resident of Bagh Ramanand, Amritsar. While two of transferees were brothers, latter was their mother. Each one except Ravinder Nayyar transferred his 1/4th share in property for consideration of Rs. 40,000. Shri Ravinder Nayyar transferred his 1/4th property for consideration of Rs. 41,000. As we have already brought out, Ashok Kumar has transferred his property vide registered deed No. 3531 on 20th Feb., 1980. Surinder Kumar transferred by registered deed No. 3555 on 1st March 1980. Shri Sham Sunder transferred his 1/4th vide registered deed no. 3660 on 10th March 1980. Shri Ravinder Nayyar transferred his interest vide sale deed No. 3790 on 22nd March 1980. competent Authority aggregated consideration received by four transferrors to sum of Rs. 1,61,000. He referred, thereafter, valuation to Valuation Cell. It has been already brought out that when Asstt. Valuation Officer inspected property on 19th Sep., 1980 building construction was in progress. He valued property at first at Rs. 6,99,000. As there was wide gap between aggregate price Rs. 1,61,000 received by transferrors and estimate of market value prepared Asstt. Valuation Officer, Competent Authority felt that apparent consideration mentioned in four registered deeds was understated. Accordingly, he having issued notice under s. 269D (1) initiated proceedings for acquiring property, under provisions contended in Chapter XXA. transferees objected to proceedings and in this connection raised several pleas. These are contained in para 7 of order of acquisition and are reproduced below: (i) That proceedings have been initiated without sufficient reasons and in absence of 'reasons to believe that there was collusion between parties to understate apparent consideration with object to avoid tax liability or concealment of any income or any asset, provisions of s. 269C (2) are not applicable to facts of case. (ii) valuation report as put by Asstt. Valuation Officer is grossly erroneous. (iii) ld. Asstt. Valuation Officer has miserably failed to identify as to which portion was constructed after purchase and which portion was already in existence as no demarcation to that effect has been shown in his report by Valuation Officer. (iv) report of Valuation Officer is self contradictory is as much as it is submitted that construction was in progress at time of inspection which was conducted by Valuation Officer as late as on 19th Sep, 1980. (v) That specifications of built up are as given by ld. Valuation Officer is irrelevant as masonary, roofing, flooring, and entire wood work and entire services were made available to impugned property after date when it was put into possession with transfers. (vi) That ld. Valuation Officer has grossly erred in not adopting plinth area as on date of transfer whereas crucial date for purpose sought to have been 19th June 1978. (vii) That sale transactions quoted by Valuation Officer are also found to be irrelevant having no nexus or any contiguity of distance with impugned property." impugned property." Competent Authority considered those pleas and found that assessment of market value could be brought down to Rs. 2,74,911. Yet he found that there was sufficient margin between actual consideration Rs. 1,61,000 and estimate value of Rs. 2,74,911. Accordingly, he passed order on 31st Dec, 1984 acquiring property. transferees have felt aggrieved and have filed three appeals, which we have consolidated for disposing them of. Learned counsel for appellants raised several contentions to impugne order. One of contentions was that order of acquisition passed was bad order as one of essential requirements for recording reasons was not followed by Competent Authority correctly. Referring to sub-s. (2) of s. 269 B he submitted that requirements laid down in sub-s. (2) were missing in reasons recorded. According to him, reasons recorded by Competent Authority were on printed form where there could be no application of mind. In this connection, he referred to order passed by this Bench in I.T. Acq. No. 1 of 1983 in case of Shri Darshan Lal Moga, etc v. IAC (Acquisition), Jalandhar, where this Bench observed "the reasons recorded on printed form where some small entries were filled in by C.A. consideration of these finding contained in acquisition order and reasons recorded in printed form do not show that IAC Acquisition had applied his mind properly." He also impugned authority of Asstt. Valuation Officer to make valuation of property. He referred to WT r. 3A in this connection. According to him, where value of property was determined at Rs. 6,98,800 it was beyond competence of Asstt. Valuation Officer to make valuation of aforesaid property. He also impugned valuation of property as grossly exaggerated. transferees had acquired only partially built property. Even when property was inspected by Asstt. Valuation Officer on 19th Sep., 1980, construction work was going on. In this view of matter, it was erroneous procedure on part of AVO to value property as finished property and then make allowance in addition made after sale of property by transferees. Therefore, it was submitted that order of acquisition was not only bad order but was made on incorrect appraisal of facts. In valuing property AVO had not taken into account that what each transaction of sale had effected was only 1/4th interest held by transferor. He should have proceeded to value 1/4th share of property rather than way he had proceeded in valuing entire property and then apportioning it into four parts representing value of interest held by four transferees. On other hand, Departmental Representative supported order of IAC (Acq.) and he submitted that counsel for assessee had not taken note of reasons recorded on other side of printed form. He had been misled by by perusing other side of page which was printed form. referred to hand scribbled note containing reasons recorded. Therefore, point he made out regarding absence of reasons recorded was not correct. As far as charge that Asstt. Valuation Officer was not entitled to make valuation of aforesaid property he read provision contained in sub-cl. (iii) of cl. (3) of WT Rule 3A. Jurisdiction of Asstt. Valuation Officer was based on value of property declared in return and not on valuation of property made by him after he was seized with jurisdiction to make valuation. As far as charge of valuing property as whole was concerned, Departmental Representative referred to fact that four registered deeds referred only to 1/4th interest in aforesaid property held by each transferor. distinct portion of property held by him was not specified. As there was not identification, it was only method which was open to Asstt. Valuation Officer to proceed in matter. As far charge that property was not properly valued because Asstt. Valuation Officer valued property as it fully constructed building it were transferees who were to be blamed who could not specify outline of building property, which was sold. Therefore, according to Departmental Representative order of acquisition passed did not show any defect and was liable to be upheld by Tribunal on consideration of facts. We have heard both sides and considered their submissions. In this connection, we first take up first plea raised by assessee regarding reasons to be recorded before initiating property proceedings. While ld. counsel for appellants referred to printed form in which reasons were recorded, Departmental Representative referred to hand scribbled not appearing on other side of form. We reproduce reasons recorded as under: "I have carefully considered V.O s report No. 1948 of 19th Oct., 1980 of A.V.O. in case of following transferees: (i) Shri Subash Vohra, Kuljit Vohra, Smt. Sumitra Devi/4th share (ii) Smt. Sumitra Devi, Kuljit Vohra & Subash Vohra /4th share In respect of property No. 138, Race Course Road, Shastri Nagar, Amritsar registered under deeds No. 3531 dt. 27th Feb., 1980, 3555 of 1st March 1980, 3660 of 10th March 1980 and 3790 of 22nd March 1980. transferees claimed before A.V.O. that there rear portion of property was old construction and remaining portion of property was constructed after purchase but no evidence was produced by them before him in course of inspection. A.V.O. has estimated value of property at Rs. 6,98,800 as against stared consideration of Rs. 1,81,000 in respect of all above mentioned four deeds. Hence, I hold and have reason to believe that these are fit cases for starting proceedings. Issue notices. perusal of these reasons recorded shows that it lags far behind requirements provided in sub. s. (1) of s. 269C for initiating proceedings to acquire property. Sub-s. (1) s. of 269 provides for Competent Authority to have reason to believe that consideration is not trully stated in instrument of transfer with object or aim of facilitating reduction or evasion of liability on part of transferor or transferees to pay tax under this Act in respect of any income arising from transfer or facilitating concealment of income or any moneys or other assets which have not been or which ought to be disclosed by transferors or transferees for purpose of Indian IT Act or this Act or WT Act. Competent Authority may subject to provisions of this Chapter initiate proceedings for acquisition of such property. perusal of reasons recorded by Competent Authority does not show that he has found reasons recorded by Competent Authority does not show that he has found object of understatement avoidance of any tax by transferors or transferees. There is no mention of object with which there could be understatement which was detected by him. Taking this view of matter. We are not persuaded that Competent Authority had properly assumed jurisdiction to initiate proceedings for acquisition of property under Chapter XXA. Therefore, without going into other pleas raised by counsel for assessee and recording our finding thereon, we have no hesitation that assumption of jurisdiction by Competent Authority was not well founded on law or facts. It is only when understatement of consideration is done with view to enable transferee or transferors to avoid tax either under IT Act or WT Act that Competent Authority is entitled to initiate proceedings for acquisition of property after recording reasons under s. 269C of t h e IT Act. understatement of consideration by itself cannot lead to finding that it was done with view to facilitate avoidance of tax either by transferor or by transferees. Taking this view of matter, we have no hesitation in striking down order as one passed in contravention of procedure laid out in Chapter XXA. We, therefore, direct that if property had already been acquired property should be released forthwith. This disposes of appeals in favour of three appellants. All appeals allowed. *** SUBHASH VOHRA & ORS. v. INSPECTING ASSISTANT COMMISSIONER OF INCOME TAX