This is group of six appeals of transferees, which came to be disposed of by common order of Competent Authority, IAC of Income-tax, Acquisition Range, Jalandhar. These appeals were heard together and are now disposed of by common order. 2. It will be necessary to state certain relevant facts. There are six sale deeds under consideration and there are six acquisition proceedings started by Competent Authority in respect of them. three sale deeds in cases of Smt. Harnam Kaur, S/Shri Bhagwan Singh & Narinder Singh and Smt. Varinder Kaur were registered on 30-3-1981 and other three sale deeds in names o f S/Shri Kala Ram and Chuni Lal, S/Shri Narinder Singh and Bhagwan Singh and Smt. Harnam Kaur were registered on 11th May 1982. All these sale deeds were in respect of immovable property belonging to single transferor Shri r ja n Dass. trasferor thus has sold his property under six different transaction to different buyers in March, 1981, and May, 1982. He had for this purpose divided his single property which was described by counsel of transferors, Shri P. N. Arora, to be plot of land with small 'Kotha' on part of it, whose value was worked out by Assistant Valuation Officer at Rs. 4,502 only. location of property as per Assistant Valuation Officer's report is corner of Maheshwari Street at Kotkapura. Competent Authority (for short C. A.) has described property as "An Ahata situated in Shastri Market / Maheshwari Street, Kotkapura. ". It is also worth noting that out of six sale deeds two of March, 1981, and May, 1982 are in favour of same buyer Smt. Harnam Kaur. She purchased 19 sq. yds. in front portion of property of transferor in March, 1981 and 88 sq. yds, of rear portion in May, 1982 for Rs. 9,500 and Rs. 14,500 respectively. Similarly, S/Shri Bhagwan Singh and Narinder Singh, who are brothers, purchased property of transferor twice, once 19 sq, yds, of front portion for Rs. 9,500 in March 1981, and again 80 sq. yds, of rear portion for Rs. 13,500 in May, 1982. There is another joint purchase of property of transferor measured 112 sq. yds. of rear portion by father and son by names S/Shri Kala Ram and Chuni Lal for Rs. 18,500 in May, 1982. remaining purchase of land of transferor measuring 19 sq. yds. in front portion was made by Smt. Varinder Kaur for Rs. 9,500 in March, 1981. Thus it will be seen that three registration deeds were in respect of joint purchasers. On our enquiry, it was stated that shares of joint owners were equal in case of sale deeds of S/Shri kala Ram and Chuni Lal, as described therein, but these were not specified in two joint sale deeds of S/Shri Bhagwan Singh and Narinder Singh. It was also told to us by Shri P. N. Arora that six purchasers were not related to each other. Another feature may also mentioned that AVO valued three pieces of land on front portion of 19 sq. yds. each together at Rs. 64,355 including therein cost of building amounting to Rs. 4,502 and it is on basis of this value of three pieces of property taken together these acquisition proceedings have been taken up and decided. In fact, taking cue from this method, C. A. concluded in para 3 of his order as follows: "Since transferor is same and property transferred vide each deed is part of one Ahata, this amounts to single deal and as such consolidated order is being passed. " In para 33, he considered all six sale transaction together on basis of one single property sold by one transferor and compared apparent consideration of Rs. 75,000 as per six sale deeds with total fair market value of Rs. 3,58,400 determined by Assistant Valuation Officer. 3. first common legal objection, which transferees' counsel, Shri P. N. Arora, took up in respect of three sale deeds of 19 sq. yds. each of March 1981 (I. T. ACQ. A. Nos. 1, 2 & 3 (ASR) /1986) was that on correct appreciation of facts about sale IAC had no jurisdiction to initiate acquisition proceedings. He submitted that all three relevant sale deeds were, in fact, of separate pieces of property, each of which was situated on front portion of property of transferor and there was no warrant for taking and considering three separate sale transaction together and clubbing sale consideration of three to apply provisions of section 269C (1) of Income-tax Act, 1961. It was contended that section 269C (1) of Act does not provide for initiating of acquisition proceedings for any immovable property fair market value of which did not exceed Rs. 25,000. It was further contended that treating each sale transaction to be in respect of separate immovable property, none of pieces of property purchased by three transferees either had apparent consideration of more than Rs. 25,000 or even fair market value determined by AVO at more than that figure. It was submitted that splitting value in round figure of Rs. 64,000 for 57 sq. yds, of land and building thereon, it will come to Rs. 21,333, which is clearly not more than limit of Rs. 25,000 prescribed in section 269C (1) of Act. In support of this submissions, attention was invited also to be Revenue's own conduct in starting three separate acquisition proceedings relating to each sale. Support was also drawn from Kerala High Court decision in case of CIT v. T. V. Suresh Chandran [1980] 121 ITR 985 and it was pointed out that High Courts had held that where immovable property was transferred by deed executed by transferors in favour of four transferres, there were four different sale transactions under which four different transferees obtained absolute right and one single proceeding for acquisition would not lie. On this short ground, it was argued that acquisition proceedings deserved to be quashed. 4. departmental representative relied on paras 3 and 22 of order of C. A. In brief, he submitted that transferor was same and property transferred under each deed was part of one Ahata and section 269C refers to fair market value of any immovable property. It was explained that in this particular case property consisted of Ahata, which had been transferred for total apparent consideration of Rs. 75,000 vide six different deeds. 5. assessee's counsel, Shri Arora, submitted in rebuttal that C. A. had wrongly described property as Ahata, which according to him, meant property enclosed by boundary wall. He pointed out that it is clear from report of AVO, made as Annexure 'B' to order of C. A., itself that property sold by transferor was not bounded by boundary wall and attention was invited to para 8 where it was clearly stated that front portion with built area was situated on front of big plot at back, which was described as Ahata and rear portion of plot was open one surrounded by residential house. It was submitted that word 'Ahata' has been used by AVO to describe big open plot at back, which was surrounded by residential house. 6. We have carefully considered submissions made by both sides. scheme of acquisition in Income-tax Act is based on each sale deed registered. property inthe comtemplation, therefore, of section 269C (1) of Act will be property, which is subject-matter of sale deed. We see no warrant either in law or in commonsense to hold that if transferor is same person and property by him, separate sale of such property in different pieces at different points or time can be ignored for purposes of initiating acquisition proceedings or taking acquisition action. sameness of transferor when sale transactions are different and to different persons is no relevant consideration. In fact, Kerala High Court in T. V. Suresh Chandran's case (supra), constructed four different sales to four different transferees even when sale deed was one. Court observed that each one of four transferees had no right and, therefore, one single acquisition proceeding based on that single deed was not held to be in accordance with section 269C (1) of Act. Thus, it follows from Kerala authority that action for acquisition could lie in respect of each transfer of any immovable property as witnessed by sale deed and not on basis of number of sale deeeds. Considering matter on this footing, three transfers witnessed by three sale deeds relating to pieces of 19 sq. yds. of property each will have to be separately judged for application of section 269C (1) of Act and test of fair market value applied. We do not find any force in line of reasoning of CA as mentioned in paras 3 and 22 of his order. It is clear to us on reading report of AVO, which is Annexure 'B' to order of CA that AVO treated open big portion of plot of transferor to be Ahata. word used is not correct inasmuch as it is clear from AVO's own report that property of transferor was not bounded by boundary wall and this is, therefore, case of some building built on front portion of big plot of land, which was largely vacant so far as rear portion was concerned and even part of front portion. CA's not understoood correct meaning of Ahata and has mechanically taken word from report of AVO, who is also misunderstood meaning but was using it to describe big plot as Ahata. Further, it is obvious that none of three sale deeds, which have given rise to IT Acquisition Appeal Nos. 1 to 3 (Asr.) /1986 is in respect of purchase, whose fair market value is more than Rs. 25,000 even as per valuation made by departmental valuer. Consequently, acquisition proceedings initiated in all three cases are improper and these are quashed. order of CA acquiring three pierces of property of 19 sq. yds. each is invalid and it is cancelled and appeals of three transferees, IT Acq. Nos. (Asr.) /1986 are allowed. 7. Next, we take up IT Acq. A. Nos. 4 to 6 (Asr.) /1986. On basis of principles laid down by Punjab and Haryana High Court covering conditions precedent for initiating acquisition proceedings, enunciated in CIT v. Amrit Sports Industries [1984] 145 ITR 231, Shri Arora submitted that, as can be seen from reasons recorded by CA in three case, which were ar pages 12 to 14 of trasferees' combined paper book, none of these proceedings had been validly initiated. He in particular attacked that CA had initiated acquisition action in three cases without applying his mind and in mechanical fashion by using stereotyped form and such action cannot fulfil condition of reason to believe prescribed in section 269C (1) of Income- tax Act. For this purpose, he read out reasons in all three cases and stated that they were identical and CA had used cyclostyled proforma filling therein certain information. It was pointed out that CA had merely looked into report of AVO given in respect of three sales of March, 1981, which are subject-matter of appeals in IT Acq. AS Nos. 1 to 3 (Asr.) /1986, and mechanically applied rate of Rs. 1,050 per sq. yd., in respect of pieces of plot sold in three sale transactions of May, 1982. Shri Arora pointed out that neither CA considered size of plots sold in May, 1982 nor location, which was very much disadvantageous and nor even location of property of sale instance, which was considered by AVO for preparing his report about, land rate to be applied in respect of three sales made in March 1981. Shri Arora referred to report of AVO, which is Annexure 'B' of order of CA to say that AVo considered sale of shop in Shastri Market near Mahaswari Street, and not of plot of land in Maheswari Street and by some process not explained derived from sale price of shop rate per sq. yd. of land underneath shop. It was conceded that if CA had applied his mind, which he was required to do to form his reasons to believe, he would not have failed to notice discrepancy in approach of AVO inthe earlier valuation report about sales in March, 1981 and further fairly advised he should have also considered location of plots sold vis-a-vis three pieces of property sold earlier in March, 1981. It was stated that barring front portion of property, there was no access to rear portion of property of transferor. It was also explained that two purchasers of front plot Smt. Harnam Kaur and S/Shri Bhagwan Singh and Narinder Singh purchased rear portions of their plots in May, 1982 and thus they had access while third purchaser S/Shri Kala Ram and Chunni Lal when they purchased back portion had no access until they purchased back portion had no access until they purchased front portion purchased by Smt. Varinder Kaur in June, 1982. It was submitted that all these facts show great importance of location in these three cases for purposes of determining fir market value. It was contended that when CA has initiated acquisition action without having any proper material or applying his mind to relevant facts, his action is nothing but mechanical action by use of stereotyped form and such as action cannot gave rise to 'reason to believe' in eye of law. In support, two decisions of Amritsar Bench of Tribunal were cited and relied upon, which were Kewal Krishan v. IAC [IT Acq. Appeal Nos. 9 to 11(Asr.) of 1985 dated 17-4-1985] and Subash Vohra v. IAC [IT Acq. Appeal Nos. 2 to 4 (Asr.) of 1985 dated 6-4-1985.] These were included in counsel's paper book. 8. In regard to joint purchase specifying equal shares made by Kala Ram and Chuni Lal [IT Acq. Appeal No. 4 (Asr.) of 1986, dated May 1986), further contention about proceedings being improper was raised on basis o f ruling of Kerala High Court in T. V. Suresh Chandran's case (supra). It w s contended by Shri Arora that one sale deed was in respect of two transactions of sale in equal share sand therefore, one single proceedings for acquisition was not justified as per section 269C (1) of Income-tax Act. 9. departmental representative, on other hand, submitted that CA had applied his mind and on basis of earlier report of AVO had entertained reason to believe. 10. On consideration of rival submissions, we find force in submissions of transferres' counsel, Shri P. N. Arora. Indeed CA has used cyclostyled form, which has used in all three acquisition proceedings, for recording that he had reason to believe on basis of certain information typed in first part of that proforma. information given in first part clearly showed that CA had acted mechanically and not applied his independent thinking either to facts and circumstances of case or to contents of report of AVO in respect of three sale transactions of March, 1981. When we look into that report, which is Annexure 'B' to order of CA, we find that sale considered is of shop in Shastri Market near Maheswari Street, which is away from pieces of land purchased by three transferees concerned in these appeals and also not back ward portion of plot situated in Maheswari Street. AVO himself stated in Maheswari Street in continuation of shastri Market and was not, therefore part of Shastri Market as is impression given while describing location at time 3 of first page of order of CA. Again that shop was sold for Rs. 26,000 and had area of 31 sq. yds. Without indicating how, from sale of built shop AVO found value of land under neath, nevertheless he fixed it at rate of Rs. 709 per sq. yd. Again from that figur e of Rs. 709 per sq. yd. he determined value of land on estimate at Rs. 1.050 per sq yds. for sale transactions made in March, 1981. If CA had indeed carefully read this report, he would not have failed to notice difficulties inherant therein. Further he neither applied his mind to location of three pieces of plot sold in May. 1982, which according to counsel of transferees, was very much disadvantageous as per his submissions noted above, nor to size of plots vis-a-vis sale instances. From angle of Revenue too, he did not attach any importance to time-gap of 14 months between March 1981 and May, 1982. He mechanically followed formula of AVO and in such circumstances, we find great substance in criticism of transferees counsel that he acted without any proper material and in mechanical fashion shutting his eyes to relevant facts of case. His action in all three cases, IT Acq. A. Nos. 4 to 6 (ASR) /1986 is not in accordance with law and he cannot be said to have formed any reason to believe. initiation of acquisition proceedings in all three cases is bad and proceedings finalised on such basis have, therefore, to be quashed and order acquiring property cancelled. We order accordingly. 11. We may also deal with additional reason advanced by Shri Arora in case of joint sale of S/Shri Kala Ram and Chuni Lal. As per decision of t h e Kerala High Court, in case of that sale, in fact, separate acquisition proceedings should have been started for shares of plot purchased by S/Shri Kala Ram and Chuni Lal and one action taken by CA was not in accordance with law. On that further ground also order in IT Acq. No. 4 (ASR) /1986 of CA is cancelled. 12. In result, three appeals, IT Acq. A. Nos. 4, 5 and 6 (ASR) /1986 also succeed and are allowed. 13. We may also clarify one more point that it is clear from our above findings that CA's approach in treating all six transactions to be single transaction is not approved by us at all and appeals have been decided by considering each transaction separately. 14. Shri P. N. Arora also wanted to argue appeals on merits but it has considered necessary when weighty legal objections about initiation of acquisition proceedings has been advanced. 15. In result, all six appeals are allowed. *** SMT. HARNAM KAUR v. INSPECTING ASSISTANT COMMISSIONER