R. JAYASIMHA BABU, J.

The petitioners are purchasers of two different items of properties from a common vendor. They are aggrieved by the order of the ITO who has declared their purchases as void by his order dt. 7th April, 1994, which concludes as under,

"Considering all the above facts, s. 281(1) of the Act, is clearly attracted in respect of the sales effected by the assessee on 6th March, 1985, and 15th July, 1987. I, therefore, treat the following sales of immovable properties effected by the assessee as"

null & void' under s. 281(1) of IT Act, 1961

(I) Property (Residential House) at Old No. 27(New No. 68) Bunder Street, Madras, sold on 6th March, 1985 to M/s Sanchetty Leasing Co. Ltd., as per document No. 222/1985 of the Registrar, North Madras

(II) Property at No. 8(Old No. 85) Varadha Muthiappan Street, Madras, sold on 16th July, 1987 to Sri. C. Balan as per document No. 827/1987 of the Sub-Registrar Sowcarpet, Madras."

2. The petitioners are the purchasers of the two properties mentioned in the order of the ITO. The assessee referred to therein is their common vendor.

3. As stated, this order was made in 1994, 9 years after the first sale and 7 years after the secon