The writ petitions under Article 226 of the Constitution have been filed challenging the orders dated 25.1.94 and 6.6.94 passed by the Assistant Commissioner of Income Tax, Circle TDS, Panbazar, Guwahati under section 201 (1) of Income Tax Act, 1961 (Annexure XIII to the CR 405 of 1994 and Annexure VI to the CR 2786 of 1994 respectively). By the order dated 25.1.94 the respondent No. 1 asked the petitioner to deposit a sum of Rs.2,80,16,800 within three days from the date of receipt of the said notice of demand as the petitioner failed to deduct tax at source in respect of the lottery draws held during the period from 16.11.93 to 31.12.93. In CR 2786 of 1994 by the impugned order dated 6.6.94 respondent No. l raised a demand of Rs.7,92,06,400 on the petitioner on account of alleged short deduction of tax at source under section 194B of the Income Tax Act in respect of 1404 Nos. of lottery draws held during the period from 6.2.92 to 12.12.92.

2. As the civil rules involve common questions of law and facts, I propose to dispose of these two writ petitions by a common judgment and order.

3. Pursuant to the powers conferred on States under Article 298 of the Constitution of India the St

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