R.L. Gulati, J.

1. This and the connected writ petition arise out of a common set of facts and involve a common question of law and they are, therefore, being disposed of by this common judgment.

2. The petitioner No. 1, Sri U. S. Awasthi, is a practising advocate at Allahabad and petitioner No. 2 is his wife. They, along with some other persons, purchased bungalow No. 15, Sarojini Naidu Marg, Allahabad, together with the vacant land. The petitioners purchased vacant land measuring about 6,000 sq. yards for a sum of Rs. 37,150.40, the price being Rs. 6.20 per sq. yard. The vendors are Sri M. L. Dave, an Assistant Secretary in the Ministry of Defence, New Delhi, and Srimati Sudha Dave, widow of late Sri C. M. Dave. The sale deed was executed and registered on 29th December, 1973. On 19th August, 1974, a notice under Section 269D(1) of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), was issued to the petitioners by the Inspecting Assistant Commissioner of Income-tax, Acquisition Range, Lucknow. It was stated in the notice that the fair market value of the property exceeded the apparent consideration thereof by more than 15 per cent, and that the full considera