1. The petitioner has by this petition prayed that the provisions of Section 143(1A)(a)(B) of the Income-tax Act, 1961, be declared as ultra vires the Constitution of India. It is also prayed that the demand raised under Section 143(1A) of the Act for a sum of Rs. 1,44,383, (annexures "P-2" and "P-3") be quashed and the notice issued on November, 16/23, 1994 (annexure "P-10"), under Section 226(3) of the Income-tax Act attaching the bank account of petitioner No. 1 in the State Bank of Indore be also quashed. Likewise, it is prayed that the notice dated September 1, 1994, annexure "P-11", issued by respondent No. 3 be quashed.

2. Petitioner No. 1 is a private limited company carrying on the business of manufacturing of drugs. Petitioner No. 2 is the managing director and the shareholder in petitioner No. 1-company and is interested in the various affairs of the company. Petitioner No. 1 filed a return showing a business loss of Rs. 14,09,666 and a carry forward of loss of the preceding two years, i.e., assessment years 1989-90 and 1990-91. Total loss inclusive of investment allowance and depreciation for three years from 1989-90 to 1991-92 is amounting to Rs. 67,17,825.

3. Re