JUDGMENT

Dalveer Bhandari, J. —

1. These appeals are directed against the judgment of the Division Bench of the High Court of Judicature at Calcutta delivered on 22nd September, 2000 in FMA No.232 of 1999.

2. Brief facts which are necessary to dispose of these appeals are recapitulated as under:

3. The assessee Belgachi Tea Company filed a writ petition in the High Court of Judicature at Calcutta under Article 226 of the Constitution. The main prayer of the writ petition is reproduced as under :

“A writ in the nature of mandamus be issued commanding the respondents to act according to law and to cancel and/or rescind and/or withdraw notices of demand dated 29.03.1984, 04.04.1984, 29.03.1985 and any proceeding taken or purported to have been taken under the Bengal Act, as amended by the Bengal Agricultural Income Tax (Amendment) Act, 1980 for the purpose of levy, imposition and collection of agricultural income tax in respect of income derived from the said tea grown and manufactured by your petitioner and further forbearing the respondents from giving any effect or further effect of proceeding in any way to enforce the impugned notices of demand dated 26.3.1984, 04.04.1984 and 29.0