DHWANIL SAUMILBHAI BHAVNAGARI vs. THE INCOME TAX OFFICER, AHMEDABAD

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SCA/5677/2022HC GujaratGJHC24016561202205 May 2022Bench: HONOURABLE MR. JUSTICE J.B.PARDIWALA,HONOURABLE MS. JUSTICE NISHA M. THAKORE43 pages
AI SummaryRemanded

What did the High Court hold?

The High Court disposed of all the captioned writ applications in terms of the Supreme Court's order in Union of India vs. Ashish Agarwal. The Supreme Court held that notices issued under the unamended Section 148 of the Income Tax Act, 1961, which were the subject matter of writ petitions before various High Courts, shall be deemed to have been issued under Section 148A of the Act. The assessing officer is required to provide information and material relied upon by the Revenue to the assessees within thirty days, allowing the assessees two weeks to reply. The requirement of conducting an inquiry under Section 148A(a) was dispensed with as a one-time measure for notices issued from April 1, 2021, to the date of the order. The assessing officers are to pass orders under Section 148A(d) thereafter and then issue notices under the substituted Section 148. All defenses available to the assessees and the Revenue under the Finance Act, 2021, and in law shall continue to be available. The Supreme Court's order is applicable PAN India and modifies similar judgments and orders passed by various High Courts. The High Court clarified that if any matter involves issues other than Section 148, liberty is granted to the writ applicant to file a fresh writ application.

What were the facts?

This judgment concerns numerous Special Civil Applications filed before the High Court of Gujarat. The petitioners are assessees challenging notices issued under Section 148 of the Income Tax Act, 1961. The Revenue is the respondent. The core issue revolves around notices issued under the unamended Section 148 of the Act, which were subsequently amended by the Finance Act, 2021. The High Court disposed of all these applications in light of a recent pronouncement by the Supreme Court in the case of Union of India vs. Ashish Agarwal. The Supreme Court's order provided a specific direction for handling such notices.

What were the issues?

1. Whether notices issued under the unamended Section 148 of the Income Tax Act, 1961, prior to the substitution by the Finance Act, 2021, are valid and can be treated as notices under Section 148A of the Act. 2. What is the procedural consequence for the Revenue and the assessees concerning such notices, including the requirement for inquiry and the issuance of show-cause notices. Assessee's Contentions: The assessees, through various learned counsels, challenged the validity of notices issued under the unamended Section 148. They relied on the pronouncements of various High Courts that had quashed such notices. Revenue's Contentions: The Revenue, represented by learned counsel including the Additional Solicitor General and Senior Standing Counsel, argued for a consistent approach across the country. They relied on the Supreme Court's decision in Union of India vs. Ashish Agarwal to seek a modification of the High Court's orders.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 149

AI-generated summary — verify with the full judgment below

C/SCA/1625/2022 ORDER DATED: 05/05/2022 IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 1625 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 19966 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 158 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 264 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 585 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 602 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 606 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 625 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 626 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 627 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 628 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 632 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 645 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 651 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 668 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 670 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 675 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 676 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 678 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 681 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 682 of 2022 With Page 1 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 750 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 758 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 773 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 775 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 795 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 818 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 820 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 828 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 857 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 858 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 863 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 866 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 895 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 898 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 907 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 910 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 911 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 919 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 937 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 946 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 948 of 2022 With Page 2 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 952 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 955 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 983 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1038 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1039 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1040 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1041 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1060 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1062 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1070 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1074 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1076 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1077 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1087 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1088 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1090 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1091 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1093 of 2022 With Page 3 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1094 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1096 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1098 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1100 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1102 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1105 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1106 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1107 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1108 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1130 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1131 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1141 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1142 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1144 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1145 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1189 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1197 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1211 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1216 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1220 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1223 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1226 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1236 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1245 of 2022 With Page 4 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1246 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1270 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1271 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1441 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1510 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1516 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1517 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1570 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1574 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1604 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1647 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1688 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1690 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1733 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1735 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1751 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1760 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1763 of 2022 With Page 5 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1765 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1767 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1775 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1779 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1781 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1784 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1785 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1786 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1789 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1790 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1793 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1819 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1821 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1852 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1854 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1907 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1950 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1954 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1957 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1958 of 2022 With Page 6 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1963 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1964 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1968 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1970 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1972 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1974 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1979 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1980 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1985 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1986 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1989 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1990 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1992 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1993 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1994 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1996 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2002 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2003 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2006 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2007 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2008 of 2022 With Page 7 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2011 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2014 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2015 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2016 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2017 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2020 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2022 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2023 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2024 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2025 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2027 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2028 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2030 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2031 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2032 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2034 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2045 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2048 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2057 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2061 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2064 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2065 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2067 of 2022 With Page 8 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2080 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2081 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2084 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2097 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2138 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2142 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2143 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2144 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2184 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2187 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2190 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2194 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2197 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2264 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2266 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2274 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2275 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2276 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2277 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2278 of 2022 With Page 9 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2279 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2280 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2281 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2282 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2283 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2284 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2285 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2286 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2287 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2288 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2289 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2290 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2291 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2292 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2294 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2342 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2349 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2350 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2453 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2464 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2480 of 2022 With Page 10 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2482 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2484 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2529 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2535 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2539 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2589 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2656 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2657 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2659 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2661 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2664 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2679 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2683 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2684 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2685 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2686 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2687 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2689 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2690 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2691 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2694 of 2022 With Page 11 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2696 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2733 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2746 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2753 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2800 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2814 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2859 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2860 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2925 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2933 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2935 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2942 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2944 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2945 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2949 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2951 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2953 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2957 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2963 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2965 of 2022 With Page 12 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2967 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2975 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2978 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2981 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2984 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2986 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2987 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2988 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2997 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2998 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3001 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3017 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3019 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3022 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3025 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3027 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3029 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3046 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3048 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3049 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3052 of 2022 With Page 13 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3053 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3054 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3055 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3057 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3059 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3061 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3062 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3063 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3064 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3066 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3071 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3089 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3091 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3093 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3095 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3097 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3099 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3102 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3104 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3105 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3106 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3107 of 2022 With Page 14 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3108 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3110 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3111 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3113 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3183 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3213 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3249 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3254 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3255 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3258 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3259 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3278 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3280 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3282 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3283 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3286 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3290 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3296 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3302 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3304 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3306 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3307 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3308 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3310 of 2022 With Page 15 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3312 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3314 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3368 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3382 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3407 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3409 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3417 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3418 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3419 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3424 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3425 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3438 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3444 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3450 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3461 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3463 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3499 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3502 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3515 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3516 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3519 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3523 of 2022 With Page 16 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3525 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3527 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3528 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3529 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3567 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3578 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3587 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3589 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3590 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3591 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3592 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3593 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3595 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3597 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3598 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3600 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3603 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3606 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3607 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3609 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3611 of 2022 With Page 17 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3612 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3614 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3617 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3619 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3621 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3622 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3627 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3628 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3631 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3632 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3634 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3635 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3636 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3638 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3639 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3641 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3645 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3647 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3652 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3657 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3676 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3728 of 2022 With Page 18 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3755 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3756 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3813 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3826 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3830 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3895 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3910 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3913 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3915 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3918 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3920 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3925 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3940 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3943 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3947 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3948 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3952 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3954 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3959 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3960 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3961 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3962 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3965 of 2022 With Page 19 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3967 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3968 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3970 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3971 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3972 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3973 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3975 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3977 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3978 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3979 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3981 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3991 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4005 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4028 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4029 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4030 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4031 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4059 of 2022 With Page 20 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4100 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4112 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4114 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4117 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4131 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4201 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4225 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4298 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4305 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4306 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4309 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4310 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4314 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4316 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4317 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4318 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4319 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4320 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4330 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4331 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4333 of 2022 With Page 21 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4339 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4341 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4344 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4346 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4350 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4364 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4365 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4366 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4367 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4369 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4370 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4371 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4378 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4380 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4386 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4387 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4388 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4390 of 2022 With Page 22 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4391 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4394 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4454 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4465 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4467 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4470 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4471 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4479 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4536 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4537 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4538 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4539 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4540 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4546 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4548 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4549 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4550 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4551 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4559 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4571 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4575 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4576 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4577 of 2022 With Page 23 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4578 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4580 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4623 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4624 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4626 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4631 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4633 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4634 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4636 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4637 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4640 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4641 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4644 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4650 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4652 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4654 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4655 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4659 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4667 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4669 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4670 of 2022 With Page 24 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4671 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4672 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4673 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4674 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4742 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4748 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4751 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4752 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4754 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4755 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4789 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4804 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4808 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4809 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4810 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4811 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4815 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4819 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4836 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4838 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4839 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4848 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4849 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4850 of 2022 With Page 25 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4853 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4859 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4861 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4867 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4872 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4873 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4875 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4879 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4881 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4882 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4883 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4887 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4891 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4897 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4899 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4926 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4933 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4934 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4935 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5039 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5073 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5075 of 2022 With Page 26 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5111 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5113 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5116 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5152 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5153 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5157 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5159 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5160 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5162 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5164 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5168 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5170 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5174 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5203 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5232 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5233 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5262 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5292 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5309 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5317 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5321 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5326 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5329 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5331 of 2022 With Page 27 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5333 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5335 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5342 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5343 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5344 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5345 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5348 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5351 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5352 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5354 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5356 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5358 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5362 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5365 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5372 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5373 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5377 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5380 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5381 of 2022 With Page 28 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5383 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5385 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5390 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5391 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5417 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5420 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5424 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5425 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5426 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5427 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5428 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5429 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5459 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5461 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5463 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5466 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5468 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5470 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5472 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5474 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5477 of 2022 With Page 29 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5478 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5481 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5483 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5486 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5489 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5490 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5492 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5494 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5506 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5508 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5510 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5511 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5512 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5582 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5586 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5605 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5613 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5667 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5677 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5687 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5689 of 2022 With Page 30 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5694 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5701 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5708 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5740 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5786 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5787 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5798 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5800 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5811 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5813 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5815 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5818 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5820 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5821 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5822 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5823 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5824 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5825 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5826 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5827 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5828 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5830 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5831 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5832 of 2022 With Page 31 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5833 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5834 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5835 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5836 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5837 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5838 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5839 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5840 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5841 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5842 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5843 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5844 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5845 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5848 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5852 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5869 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5871 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5873 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5879 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5881 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5882 of 2022 With Page 32 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5884 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5885 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5887 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5888 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5890 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5892 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5894 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5905 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5914 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5916 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5920 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5922 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5924 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5930 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5983 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5987 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5988 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5990 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5997 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6011 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6013 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6023 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6025 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6029 of 2022 With Page 33 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 6032 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6161 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6162 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6163 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6165 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6167 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6169 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6170 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6172 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6174 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6176 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6177 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6178 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6179 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6181 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6182 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6184 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6185 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6187 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6189 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6199 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6268 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6270 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6271 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6273 of 2022 With Page 34 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 6275 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6301 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6302 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6318 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6319 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6321 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6325 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6333 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6348 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6350 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6351 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6356 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6357 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6381 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6385 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6386 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6388 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6399 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6400 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6402 of 2022 With Page 35 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 6403 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6404 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6405 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6406 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6451 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6452 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6453 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6460 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6478 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6481 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6484 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6486 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6494 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6514 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6527 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6532 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6535 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6536 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6537 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6540 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6591 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6592 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6593 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6594 of 2022 With Page 36 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 6621 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6719 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6726 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6813 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6817 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6834 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6877 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6878 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6880 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6905 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 6907 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7161 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7170 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7217 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7219 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7222 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7224 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7320 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7339 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7399 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7401 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7418 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7430 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7431 of 2022 With Page 37 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 7432 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7433 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7434 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7435 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7437 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7438 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7443 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7476 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7608 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7634 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7637 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7640 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7642 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7831 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7994 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8009 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8019 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8020 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8033 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8034 of 2022 With Page 38 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 8192 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8233 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8235 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8242 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8244 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8345 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8346 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8359 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8386 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8520 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8523 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8527 of 2022 ========================================================== KANJANI MANOHARLAL BANSILAL HUF THRO MANOHARLAL BANSILAL KANJANI Versus UNION OF INDIA ========================================================== Appearance: FOR THE RESPECTIVE WRIT APPLICANTS IN THEIR RESPECTIVE WRIT APPLICATIONS: MR. TUSHAR HEMANI, SENIOR COUNSEL WITH MS. VAIBHAVI PARIKH; MR. TIRTH NAYAK, MR. VIJAY RANJAN, DARSHAN GANDHI, MR. AVINASH PODDAR, MR. MANISH J. SHAH, MR. TEJ SHAH, MR. DARSHAN R. PATEL, MR. DHINAL A. SHAH, MR. S. N. DIVATIA, MS. ARCHANA ACHARYA, MR. B. S. SOPARKAR, MR. MOHIT BALANI, MR. PRIYAM SHAH, MS. KAMYA MANIT SHAH, MR. HIREN J. TRIVEDI, MS. SHRUNJAL T. SHAH, MR. SUDHIR M. MEHTA WITH MS. SHAILEE S. MEHTA, MR. HITENDRA D. RAJPUT, MS. DIVYA AGRAWAL, MR. VIJAY H. PATEL, MR. JAIMIN A. GANDHI WITH MR. SWAPNESHWAR GOUTAM, MR. UMAIDSINGH BHATI, MR. HARDIK P. MODH, MR. HARDIK V. VORA, MR. DILIP L. KANOJIYA, MR. JEET JOTANGIA, MR. Page 39 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 JIMI S. PATEL, MR. AADIT R. SANJANWALA, MR. NIRAV P. SHAH, MR. APURVA N. MEHTA, MR. RAJ S. TANNA, MR. KETAN H. SHAH, MR. TARAK DAMANI, MR. ADITYA A. BIHANI, MS. NOOPUR K. DALAL, MR. KUNAL B. GOYAL, MR. NIMIT Y. SHUKLA, MR. UDIT D. MEHTA, MR. ABHISHEK M. MEHTA, MR. B. C. THAKKAR, MR. JAIMIN R. DAVE, MR. PARV S. GUPTA, MR. NIRAV C. THAKKAR, MR. S. P. MAJMUDAR, MR. ADITYA A. GUPTA, MR. MOHIT A. GUPTA AND MS. NUPUR D. SHAH, ADVOCATES FOR THE RESPONDENTS - REVENUE (INCOME TAX DEPARTMENT) IN THEIR RESPECTIVE WRIT APPLICATIONS: MR. DEVANG VYAS, ADDITIONAL SOLICITOR GENERAL OF INDIA APPEARING FOR THE UNION OF INDIA; MR. M. R. BHATT, SENIOR COUNSEL WITH MR. KARAN SANGHANI, LEARNED COUNSEL FOR M R BHATT & CO.(5953) MR. VARUN K. PATEL, SENIOR STANDING COUNSEL; MS. KALPANA K. RAVAL, SENIOR STANDING COUNSEL WITH MR. NIKUNT K. RAVAL, STANDING COUNSEL NOTICE SERVED for the Respondent(s) No. 1 ========================================================== CORAM:HONOURABLE MR. JUSTICE J.B.PARDIWALA and HONOURABLE MS. JUSTICE NISHA M. THAKORE

Date : 05/05/2022

COMMON ORAL ORDER (PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA) 1 We have heard Mr. Tushar Hemani, the learned Senior Counsel assisted by Ms. Vaibhavi Parikh; Mr. Tirth Nayak, Mr. Vijay Ranjan, Darshan Gandhi, Mr. Avinash Poddar, Mr. Manish J. Shah, Mr. Tej Shah, Mr. Darshan R. Patel, Mr. Dhinal A. Shah, Mr. S. N. Divatia, Ms. Archana Acharya, Mr. B. S. Soparkar, Mr. Mohit Balani, Mr. Priyam Shah, Ms. Kamya Manit Shah, Mr. Hiren J. Trivedi, Ms. Shrunjal T. Shah, Mr. Sudhir M. Mehta with Ms. Shailee S. Mehta, Mr. Hitendra D. Rajput, Ms. Divya Agrawal, Mr. Vijay H. Patel, Mr. Jaimin A. Gandhi with Mr. Swapneshwar Goutam, Mr. Umaidsingh Bhati, Mr. Hardik P. Modh, Mr. Hardik V. Vora, Mr. Dilip L. Kanojiya, Mr. Jeet Jotangia, Mr. Jimi S. Page 40 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 Patel, Mr. Aadit R. Sanjanwala, Mr. Nirav P. Shah, Mr. Apurva N. Mehta, Mr. Raj S. Tanna, Mr. Ketan H. Shah, Mr. Tarak Damani, Mr. Aditya A. Bihani, Ms. Noopur K. Dalal, Mr. Kunal B. Goyal, Mr. Nimit Y. Shukla, Mr. Udit D. Mehta, Mr. Abhishek M. Mehta, Mr. B. C. Thakkar, Mr. Jaimin R. Dave, Mr. Parv S. Gupta, Mr. Nirav C. Thakkar, Mr. S. P. Majmudar, Mr. Aditya A. Gupta, Mr. Mohit A. Gupta and Ms. Nupur D. Shah, the learned counsel appearing for the respective writ applicants in their respective writ applications and Mr. Devang Vyas, the learned Additional Solicitor General of India appearing for the Union of India; Mr. M. R. Bhatt, the learned Senior Counsel assisted by Mr. Karan Sanghani, the learned counsel; Mr. Varun K. Patel, the learned Senior Standing Counsel; Ms. Kalpana K. Raval, the learned Senior Standing Counsel with Mr. Nikunt K. Raval, the learned Standing Counsel appearing for the respondents - Revenue (Income Tax Department) in their respective writ applications. 2 All the captioned writ applications are ordered to be disposed of in view of the recent pronouncement of the Supreme Court in the case of Union of India and others vs. Ashish Agarwal (Civil Appeal No.3005 of 2022 and allied appeals decided on 4th May 2022). We quote the relevant observations made by the Supreme Court as under: “10. In view of the above and for the reasons stated above, the present Appeals are ALLOWED IN PART. The impugned common judgments and orders passed by the High Court of Judicature at Allahabad in W.T. No. 524/2021 and other allied tax appeals/petitions, is/are hereby modified and substituted as under: - (i) The impugned section 148 notices issued to the respective assessees which were issued under unamended section 148 of the IT Act, which were the subject matter of writ petitions before the various respective High Courts shall be deemed to have been issued under section 148A of the IT Act as substituted by the Finance Act, 2021 and construed or treated to be show-cause notices in terms of section Page 41 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 148A(b). The assessing officer shall, within thirty days from today provide to the respective assessees information and material relied upon by the Revenue, so that the assesees can reply to the show-cause notices within two weeks thereafter; (ii) The requirement of conducting any enquiry, if required, with the prior approval of specified authority under section 148A(a) is hereby dispensed with as a one-time measure vis-a-vis those notices which have been issued under section 148 of the unamended Act from 01.04.2021 till date, including those which have been quashed by the High Courts. Even otherwise as observed hereinabove holding any enquiry with the prior approval of specified authority is not mandatory but it is for the concerned Assessing Officers to hold any enquiry, if required; (iii) The assessing officers shall thereafter pass orders in terms of section 148A(d) in respect of each of the concerned assessees; Thereafter after following the procedure as required under section 148A may issue notice under section 148 (as substituted); (iv) All defences which may be available to the assesses including those available under section 149 of the IT Act and all rights and contentions which may be available to the concerned assessees and Revenue under the Finance Act, 2021 and in law shall continue to be available. 11. The present order shall be applicable PAN INDIA and all judgments and orders passed by different High Courts on the issue and under which similar notices which were issued after 01.04.2021 issued under section 148 of the Act are set aside and shall be governed by the present order and shall stand modified to the aforesaid extent. The present order is passed in exercise of powers under Article 142 of the Constitution of India so as to avoid any further appeals by the Revenue on the very issue by challenging similar judgments and orders, with a view not to burden this Court with approximately 9000 appeals. We also observe that present order shall also govern the pending writ petitions, pending before various High Courts in which similar notices under Section 148 of the Act issued after 01.04.2021 are under challenge. 12. The impugned common judgments and orders passed by the High Court of Allahabad and the similar judgments and orders passed by various High Courts, more particularly, the respective judgments and orders passed by the various High Courts particulars of which are Page 42 of 43

C/SCA/1625/2022 ORDER DATED: 05/05/2022 mentioned hereinabove, shall stand modified/substituted to the aforesaid extent only. All these appeals are accordingly partly allowed to the aforesaid extent. In the facts of the case, there shall be no order as to costs.” 3 In view of the aforesaid, all the writ applications stand disposed of in terms of the aforesaid order passed by the Supreme Court. 4 We clarify that in any particular matter if there is any other issue other than Section 148 of the Income Tax Act, 1961, then we reserve the liberty in favour of that particular writ applicant to file a fresh writ application in accordance with law. (J. B. PARDIWALA, J) (NISHA M. THAKORE,J) CHANDRESH Page 43 of 43

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