Allowing the petition the Court held that the provisions of section 269UD are to be strictly construed, there is no power to extend time lines stipulated in the provision. Thus the transferors and the transferee did not have adequate opportunity to put forth their objections apart from failure to furnish the copy of the valuation report of the subject property as done by the Department. The documents pertaining to the three sale instances which were referred to in the show-cause notice were also not provided. There had been gross violation of principles of natural justice which would be sufficient to set aside the order passed by the appropriate authority. The transferors and the transferee contended that the appropriate method of valuation shall be the rent capitalisation method. The appropriate authority rejected such contention. The Appropriate Authority had two options firstly to examine and ascertain as to whether there was a valid tenancy or to hold that there is no tenancy subsisting. There could not be a conclusion, that the tenancy was not recognised and there is no such power vested with the Appropriate Authority by piercing into the transactions which were much ahead of the agreement for sale. The Appropriate Authority has no right to question the validity of the agreement for sale, nor can it go into the legality of the transaction or the title of the vendors. The specific plea of the transferors as regards the compelling circumstances to sell the property was not noted by the Appropriate Authority. The other factors which diminished the value of the property were not taken into consideration. The assessee was not provided with the copies of the relevant documents pertaining to the three properties which were referred to as the sale instances to arrive at the value of the subject property. There had been gross violation of principles of natural justice and a perversity in the approach of the authority and failure to take into consideration relevant materials, ignoring settled legal principles more particularly regarding the valuation of the property. The order passed under section 269UD was not valid.