Allowing the petition  the Court held that  issuance of a show-cause notice was not an empty formality. Its purpose was to give a reasonable opportunity to the affected persons to contend that the apparent consideration under the agreement to sell the property was the market price or that there was no undervaluation because of peculiar facts. There was no finding that the undervaluation was intended to evade tax, let alone discharging the onus of establishing that undervaluation was with a view to evade tax. In the third order of the Appropriate Authority, it was only stated that the transaction under consideration was proposed to take place at a rate lower than the fair market value by more than 15 per cent. considering the fair market value determined by the Appropriate Authority. On this ground alone, the order was quashed and set aside. The view taken by the Appropriate Authority was palpably erroneous and could not stand the scrutiny of law even on the merits. The Valuation Officer had noted on April 22, 1991 and the Deputy Commissioner (Appropriate Authority) had noted on April 24, 1991 that the property was not under-valued. The Appropriate Authority had not stated in the reasons recorded in 1991 why it did not accept these two reports. The Appropriate Authority had not stated anywhere why he was not accepting the three comparables mentioned by the Valuation Officer and had not given the basis for comparing the properties SF and NA with the property in question, when those two properties were farther away than the three properties used by the Valuation Officer to compare. In any case, the valuation of the property NA used in the first order dated April 29, 1991 by the Appropriate Authority was only about 9 per cent. more compared to the property in question. The mathematical calculations by adding and subtracting advantages and disadvantages to arrive at a conclusion that there was undervaluation in excess of 15 per cent. limit could be stated to be far from being honest. This 15 per cent. limit also could not be applied mechanically but a reasonable margin of error had to be considered. Since the difference was only about 9 per cent. the Appropriate Authority for reasons which were obvious, in the supplementary show-cause notice read with the statement of valuation annexed thereto, had resorted to mathematical calculations and by adding and subtracting advantages and disadvantages had arrived at a conclusion that there was undervaluation in excess of 15 per cent. which was most improper on his part. He had not explained anywhere why the two properties of SF and NA were chosen as comparables and from where the details of those two properties were obtained. The Appropriate Authority ought to have disclosed everything in a transparent manner to enable the assessee to effectively respond. There was also no finding that the undervaluation was intended to evade tax which was mandatory vitiating the stand of the respondents. Even assuming that there was a difference of 15 per cent., the Appropriate Authority could not assume jurisdiction under section 269UD automatically. Various factors determined the price for a property such as demand, supply, terms of payment, the urgency for the seller to sell or for the buyer to buy, relationship between parties, dominance of a party etc. None of these were considered by the Appropriate Authority. Therefore, the third order of the Appropriate Authority under section 269UD was set aside. Court also held that Transferee has a right to challenge order of  purchase.