Appropriate Authority & Commissioner ... vs Smt. Varshaben Bharatbhai Shah & Ors

The Supreme Court upheld the High Court's decision that the provisions of Chapter XX-C of the Income Tax Act, 1961, were not applicable to the transfer of property between co-owners where each co-owner received less than Rs.25 lakhs. The Court emphasized that the appropriate authority's order of pre-emptive purchase was quashed due to a violation of natural justice, as the Revenue failed to provide necessary valuation reports. The ruling followed the precedent set in K.V. Kishore & Anr. vs. Appropriate Authority & Ors. (189 I.T.R. 264).