Allowing the appeal of the revenue the Court held that , Notice need not specifically mention Explanation. As regards addition as unexplained investment as the assesse has not produced any material to substantiate the claim , levy of penalty was held to be justified .Court also observed that present respondent being a legal heir of the assesse , recovery would be made only to the extent of the estate of the assesse capable of meeting the liability as provided in S. 159(6) of the Act. (AY. 1990-91)