V.K. SINGHAL, J.--The validity s. 143(1A) of the IT Act, 1961, has been assailed in all these writ petitions, on the ground of liability of additional tax being violative of the principles of natural justice, discriminatory, arbITRary, unreasonable and as such are in violation of Arts. 14 and 265 of the Constitution of India. The provisions of s. 143(1A) are as under:

"Sec. 143(1A)(a): Where, in the case of any person, the total income, as a result of the adjustments made under the proviso to cl. (a) of sub-s. (1), exceeds the total income declared in the return by any amount, the AO shall,-

(i) further increase the amount of tax payable under sub-s. (1) by an additional Income Tax calculated at the rate of 20 per cent of the tax payable on such excess amount and specify the additional Income Tax in the intimation to be sent under subcl. (i) of cl. (a) of sub-s. (1);

(ii) where any refund is due under sub-s. (1) reduce the amount of such refund by an amount equivalent to the additional Income Tax calculated under sub-cl. (i)

(b) where as a result of an order under s. 154 or s. 250 or s. 254 or s. 260 or s. 262 or s. 263 or s. 264, the amount on which additional Income Tax is payab