JUDGMENT

B.C. Patel, C.J.

1. One Sheesh Ram, the original claimant in certain land acquisition proceedings, along with Ram Swarup moved the reference Court (Addl. District Judge, Delhi) in LAC No. 134 of 1990. It transpires that during the pendency of those proceedings, Sheesh Ram died on 3rd Aug., 1986. His seven legal heirs were brought on record in the proceedings before the Addl. District Judge, Delhi who ultimately made an order on 25th Jan., 1994; awarding compensation for the lands acquired at the rate of Rs. 76,550 per bigha, solarium, along with other benefits.

2. The present petition is directed, inter alia, against the notice of demand under Section 156 of the IT Act, 1961 (hereinafter for short "the Act") issued by the IT Department, a copy of which is produced at p. 26 of the paper book. The notice is in the name of Braham Parkash, legal heir of Sheesh Ram for the asst. yr: 1996-97 raising a demand of Rs. 57,75,545. Thereafter, a notice, which is also impugned, under Section 221(1) of the Act was issued on 19th June, 2003, a copy of which is at p. 29, Annex. 2. It is addressed to Braham Parkash calling upon him to show cause as to why a penalty should not be impos