JUDGMENT

TULZAPURKAR, J.:—These two appeals by certificates granted by the High Court of Andhra Pradesh raise the question of legality and/or validity of two notices issued by the Assistant Controller of Estate Duty, Hyderabad, one under S. 59 (a) and the other under S. 61 of the Estate Duty Act, 1953 (hereinafter called the Act).

2. Two parcels of agricultural land (admeasuring 22 acres 24 guntas and 8 acres 23 guntas) situated in Moosapet village, belonging to one Rashid Shapoor Chenai were, during his lifetime, acquired for the Synthetic Drugs Project factory of the Indian Drugs and Pharmaceutical Ltd. by the Andhra Pradesh Government by Notifications issued on June 19, 1961 and January 13, 1962 under the Land Acquisition Act. Possession of the lands was taken in January 1963 and by two separate awards both made on January 31, 1963 the Special Deputy Collector of Land Acquisition awarded a total compensation of Rs. 20,000. This compensation was received by Rashid himself during his lifetime. Later two more parcels of agricultural land (admeasuring 131 acres 10 guntas and 224 acres 22 guntas) situated at Qutbillapur in Madchal Taluk belonging to Rashid were acquired for Hindustan