M/s.Meghana Avenues Private Limited, vs. The Commissioner of Income Tax (Appeals),
What did the High Court hold?
The High Court allowed the writ petition, setting aside the penalty order dated October 19, 2022, and the appellate order dated June 4, 2025. The Court relied on the Supreme Court's decision in *Commissioner of Income Tax vs. Jai Laxmi Rice Mills*, which concurred with the view that satisfaction must be recorded in the assessment order for the initiation of penalty proceedings under Section 271E (and by extension, Section 271D, as they are pari materia). The Court noted that the issue of whether penalty can be levied by the Joint Commissioner without satisfaction recorded in the assessment order was directly addressed in *Srinivasa Reddy Reddeppagari*, a coordinate bench decision. The Court found no grounds for the Revenue to take a different view. The Court also referenced the CBDT Circular No. 9/DV/2016, which, based on the Kerala High Court's decision in *Grihalakshmi Vision*, suggested that the Joint Commissioner is the competent authority to initiate penalty proceedings, but this was considered in light of the Supreme Court's pronouncement on the requirement of satisfaction in the assessment order. The Court found the penalty initiation by the Joint Commissioner without such satisfaction to be without jurisdiction.
What were the facts?
The petitioner, M/s. Meghana Avenues Private Limited, is challenging a penalty of Rs. 40,50,000 imposed under Section 271D read with Section 274 of the Income Tax Act, 1961, for the assessment year 2017-18. The penalty was initially imposed by the National Faceless Assessment Centre and upheld by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC). The petitioner's return for AY 2017-18 declared a total income of Rs. 8,60,110. Proceedings under Section 147 were initiated, and assessment was completed on March 15, 2022. The Joint Commissioner of Income Tax issued a notice under Section 274 read with Section 271D on April 28, 2022, alleging contravention of Section 269SS. The petitioner contends that penalty proceedings should have been processed through the Faceless Penalty Scheme and that the Joint Commissioner lacked the authority to initiate penalty proceedings without satisfaction recorded in the assessment order.
What were the issues?
1. Whether penalty proceedings under Section 271D of the Income Tax Act, 1961, can be initiated on satisfaction recorded by the Joint Commissioner upon perusal of assessment records, instead of by the assessing officer. (Question of law) Assessee's arguments: - Penalty proceedings must be processed through the Faceless Penalty Scheme, effective from January 12, 2021. - The penalty was initiated by the Joint Commissioner on April 28, 2022, and concluded by the Faceless Penalty Unit on October 19, 2022. - Relied on *Srinivasa Reddy Reddeppagari vs. Joint Commissioner of Income Tax* (Telangana High Court) and *Grihalakshmi Vision vs. Additional Commissioner of Income Tax* (Kerala High Court), arguing that satisfaction must be recorded in the assessment order for penalty initiation. - Cited *Commissioner of Income Tax vs. Jai Laxmi Rice Mills* (Supreme Court) and *Grandhi Sri Venkata Amarendra vs. Joint Commissioner of Income Tax* (Andhra Pradesh High Court) to support the requirement of assessing officer's satisfaction in the assessment order. - Argued that the appellate authority failed to appreciate written contentions and proceeded without hearing, violating natural justice. Revenue's arguments: - The petitioner has an efficacious alternative remedy of appeal before the Income Tax Appellate Tribunal (ITAT).
Which sections of the Income-tax Act were involved?
Section 271D,Section 274,Section 147,Section 148,Section 269SS,Section 273B,Section 144B,Section 275(1)(c),Section 271E
AI-generated summary — verify with the full judgment below
Cause title — parties, addresses and appearances
The Court made the following: ORDER
a AT HYDERABAD AND Dated: Of.03.2026 Between: IWs.Meghana Avenues Private Limited, Rep. by its Director Sri B.Venkat Reddy .Petitioner and The Commissioner of [ncome Tax (Appeals)' National Faceless Appeal Centre (NFAC)' lncome Tax Department, Delhi and four others Respondents ORDER: Mr. B.Krishna Reddy, learned counsel for the petitioner' Mr. K.Sudhakar Reddy, learned Senior Standing Counsel for the lncome Tax Department for respondent Nos'l to 4' 2.WhetherpenaltyproceedingsunderSectionzTlDofthelncome Tax Act, t96t can be initiated on satisfaction being recorded by the Joint commissioner on perusal of the assessment records instead of the assessing offrcer is the question involved in the present writ petition? )
I 2
Ttre order passed by the first respondent/National Faceless Appeal centre (NFAC) dated 04.06.202s for rhe assessment year 2ol7-lg upholding the order passed by the second respondent/National Faceless Assessm,:nt centre dated lg.l0.zo22, whereby p.nut,y of Rs.40,50,000/- was imp,lsed upon the petitioner under Section 27lD read with Section 274 of ttre Income Tax Act, 196l (hereinafter reflemed to as.the Act') is under ch;lllenge in the present writ petition.
The facts relevant for consideration of this issue are briefly stated as under: (i'r The petitioner/assessee had filed its retum of income for the assessment year 2017-18 on 04.11.2017 declaring total income of Rs.8,60,t1004. The assessee had deposited Rs.14,39,000/- in his bank accounts during the period of demonetization. Accordingly, proceedings under Section 147 of the Act were initiated. Notice under Section 148 of the Act was issued on 31.03.2021 after approval of the competent authoritl'. The assessment was completed on 15.03.2022. (ii) The third respondent/Joint commissioner of lncome Tax issued n,otice under section 274 read with section 27lD of the Act on 28.04.2022 on the basis of information available with the department that transacti'Jns carried out by the assessee were in contravention of ) J
3 I provisions of section 26955 of the Act. Accordingly, penalty of Rs.40,50,00,000/- was levied on the assessee. The petitioner challenged it in appeal before the first respondent. The said appeal was disposed of on 04.06.2025 confirming the penalty under section 27-lD of the Act' The petitioner has assailed it on the ground that the penalty proceedings must be processed through the Faceless Penalty Scheme with effect from t2.01.2021. However, it was initiated by the Joint commissioner of lncome Tax, Range-5, Hyderabad on 28.04.2022 and concluded by the Faceless Penalty Unit on lg.l}.2)
Learned counsel for the petitioner has relied upon the case of srinivasa Reddy Reddeppagari vs' Joint commissioner of Income Tax, central circle, central Range-2 (w.P.No.44285 of 2ozz,dated 26.12.2022)r and submitted that the issue whether without satisfaction being recorded in the assessment order' penatty can be levied by the Joint Commissioner under Section 27lD of the Act was decided in favour of the assessee by this Court' The judgmenr, CBDT Circular No.9/DV/2016, dated 26.04.2016 was issued to the effect that the assessing officers, below the rank of Joint I ManuJTLl2245l2022 2 [ZOtSl 63 taxmann.com 196 (Kerala) ) 1
4 Commissioner, may be advised to make a reference to the Range Head regarding any violation of the provisions of Section 26955 and Section 269T of t-he Act, as the case may be, in the course of the assessment \ \ 3 lzors; 3;'9 ITR 52t (sc) o lzoz+132.t crR (Ap) 947
.{.lh ,j I 5 -1 penalty under Section 27lDof the Act. Section2TlD penalises taking or accepting any loan or deposit otherwise than by account payee cheque/drafl/electronic clearance above Rs.20,000/-. However, it is subject to exception of reasonable cause under Section- 2738 of the Act' Learned counsel for the petitioner has further argued that the appellate authority chose not to appreciate the detailed written contentions submitted in the Grounds of Appeal and proceeded to frnalise the appeal stating that the authorised representative of the appellant had not filed any written submissions or appeared before him. This is against the principles of natural justice. The petitioner also relied upon the decision in respect of discharge of burden under Section 105 of the Evidence Act, 1872' such The respondent Department has f,rted a counter affidavit' Learned counsel for the Revenue has opposed the rvrit petition on the ground that the petitioner has an effrcacious alternative remedy by way of appeal before the learned lncome Tax Appellate Tribunal (trAT) against the orderpassedbytheCommissioneroflncomeTax(Appeal),National Faceless Appeal centre conftrming the imposition of penalty under Section 27lD of the Act. tt has also taken a plea that the Faceless Penalty Scheme, 2021 provides for faccless conduct of penalty proceedings' t RtR t9z+ sc l57o I
6 However, it nowhere prohibits or invalidates the issuance of show cause notice or initiation of penalty proceedings by the jurisdictional authority where initiated in accordance with law. The initiation of proceedings under S,sction 274 read with Section 27lD of the Act by the Joint commissioner, who is the prescribed authority under Section 27ID(Z)is therefore: valid and within jurisdiction. [t is fully in accordance with the statutory mandate. The F'aceless Penalty Scheme is meant to regulate officer. unlike the provisions of section 27\(l)(c), under the provisions section 27lD and2T lE of the Act, the exclusive authority is conferred on o 1tttz1 86 trR 557 \
!fl!! .l:l r!t. 7 'l t the Joint commissioner. Therefore, the principles laid down in the case of D.M.Manasvi(supra)cannotbecalledinaidtoimpugntheconcurrent frndings of the lower authorities. Learned counsel for the Revenue has also referred to order of the learned IT$T' Mumbai in l.T.A.No.139/Mum/2ol2.ItissubmittedthatthelearnedITAThas examinedtheissueindetailbyalsoreferringtothejudgmentoftheJai Laxmi Rice Mills (supra) and observed that in the said case' the penalty proceedings were initiated by the assessing offrcer during the course of assessment proceedings and the assessment order was passed to the best of his judgment under Section 144 of the Act. The said ax parte order was setasidebythelearnedClT(Appeals)andtheassessingofficerwas directed to frame the assessm ent de novo. However, the assessing officer passedpenaltyorderunderSectionzT:lDoftheActonthebasisofthe observations made in the original assessment order' The High court took theviewthattheproceedingsunderSection27|DoftheActarenot independentproceedingsandthepenaltyorderwouldpractically submergeinviewoftheorderpassedbytheCommissioneroflncome Tax(Appeals).Theoriginalassessmentorderwassetasideandthecase was remanded for de novoassessment. since the assessing officer did not refer ro the violation of provisions of Section 26955 and 269T of the Act in the said proceedings, the Tribunal deleted the penalty' The High court I i , : I I I I I i I i i i i / /
8 did not admit the appeal on the ground that no substantial questions of law arose. Hence, the limited question urged before the apex court was whether the penalty proceedings under Section 27lD of the Act is independent of assessment proceedings. This question arose for consideration in respect of assessment years l99l-92 and, 1992-93. The Tribunal held that the issue before the apex court was not related to recording of satisfaction, but whether the penalty proceedings under Section 27lD of the Act are independent of assessment proceedings. Since the original assessment order, in case of which the impugned penalty proceedings were initiated, had been set aside, the apex court upheld tht: view of the High Court that the penalty proceedings should not have beer, continued on the strength of the assessment order so set aside. Hence, all the observations made by the apex court were related to the question posed before it. It is submitted that the decision of the apex court in Jai Larmi Rice Mills (supra) has to be understood in that context. It is further submitted that in the present case, original assessment proceedings have not been set aside. The penalty proceedings have been initiated by the competent authority under Section 27lD of the Act on the basis of the facts nan'ated by the assessing offrcer in the said proceedings. Therefore, the impugned proceedings are not susceptible to challenge on the point of jurisdictir>n of the Joint Commissioner of Income Tax. i I i
!It5 9 .l i I IlI ,l I :l I 1 t T.Wehaveconsideredthesubmissionsofthelearnedcounselforthe parties and Perused the records' 8.Thefactstakennoteabovedisclosesthat.thereassessment proceedingswereclosedwithoutanyadditiontotheincomeofthe assessee'[talsodisclosesthattherewasnoreferencetotheJoint commissioner of lncome Tax to initiate penalty proceedings under Sectionz|.iDoftheActintheorderofassessment.TheJoint CommissioneroflncomeTax,thereafterissuednoticedated2S.04.2022 requiring the petitioner to explain as to why penalty under Section 27lD oftheActshouldnotbeleviedforviolationoftheprovisionsofsection 26gssoftheAct.TheappellantsubmittedexplanationbeforetheJoint commissioner of [ncome Tax. It is submitted that lands sold at Nakrekal' Nalgonda District and Mahaboobabad District were purchased by persons whowerenon-taxassessees.Theamountsreceivedbythefarmerswere accepted by the assessing offrcer as genuine. The assessing officer did not dispute the genuineness of the transactions' The assessing officer did not initiate proceedings under Section 27lD of the Act or any other penalty proceedings. The amounts were received against the sale of property and werepartofamountsrecordedintheregistereddocuments.Theincome from the said transactions was also disclosed in the returns of income and ,l i I I I I I I 1'l rl il rilii it il ,t / ii ii I i I ; / I I I
l0 I I was accepted by the assessing officer. The Joint Commissioner of [ncome Tax did not accept the explanation and levied penalty of Rs.40,50,000/- under Section 27lD of the Act. The order of the Joint Commissioner was upheld by the National Faceless Appeal Centre, Delhi observing that the appellant despite several opportunities had failed to make any submissions in support of the appeal. Therefore, it was not interested in prosecuting the appeal. The appellate authority quoted number of judgments on the point that if an assessee fails to participate in the proceedin.gs and it has not adduced in evidence, the appeal is liable to be disrnissecl. The appeal was accordingly dismissed upholding the order of the Joint,Commissioner.
Ar; referred to in the opening paragraph of this judgment, the question posed t<l be answered is whether in the absence of any satisfaction rccorded by the assessing oflicer for initiation of penalty or referring the matter for initiation of penalty proceedings, the Joint Commisr;ioner for lncome Tax could in exercise of the power under Section .271D(2) of the Act initiate the proceedings on its own on the ground of violation of Section 26955 of the Act.
S,:ctions 26955 and 27lD of the Act are extracted hereunder for ) ) appreciation of the issue involved in this case.
fi i I : :; ' I l1 "section 269-55 of the Act: 269-55. Mode of taking or accepting certain loans, deposits and specified sum:- No peison shaLl take or accept from any other plr.on (herein referred to as the depositor), any loan or deposit or any specified sum, otherwise than by an account payee cheque or account payee bank draft or use of electronic clearing system through a bank account or through such other electronic mode as may be prescribed, if,- (a) the amount of such loan or deposit or specified sum-or the aggregate amount of such loan, deposit and specified sum; or (D)onthedateoftakingoracceptingsuchloanordepositor splcified sum, any loan or deposit or specified sum taken or accepted earlier by such person from the depositor is ."*"iningunpaid(whetherrepaymenthasfallendueornot), the amount or the aggregate amount remaining unpaid; or (c) the amount or the aggregate arnount referred to in clause (a) together with the amount or the aggregate amount refened to in clause (D), is twentY thousand rupees or more: Provided that the provisions of this section shall not apply to any loan or deposit or ipecified sum taken or accepted from, or any loan or deposit or specified sum taken or accepted by,- (a) the Government; iai unv banking company, post office savings bank or co- operative bank; (c) any corporation established by a Central, State or Provincial Act; (A any Government company as defined in clause (a5) of Section 2 of the Companies Act,20l3 (18 of 2013); (e) such other institution, association or body or class of institutions, associations or bodies which the Central Government may, for reasons to be recorded in writing' noti$ in this behalf in the Official Gazette: provided further that the provisions of this section shall not apply to any loan or deposit or specified sum, where the person from whom the loan or deposit or ipecified sum is taken or accepted and the person by whom the loan or deposit or specified sum is taken or u"""pt"O, are both having agricultural income and neither of them has any income chargeable to tax under this Act'
lr t2 Provided also that the provisions of this section shall have effect, as if for the words "twenty thousand rupees", the words "two lakh rupees" had been substituted in the case of any deposit or Ioan rvhere,- (a) such deposit is accepted by a primary agricultural credit society or a primary co-operative agricultural and rural development bank from its member; or (D) such loan is taken from a primary agricultural credit societl, or a primary co-operative agricultural and rural development bank by its member. Explanation - For the purposes of this section,- (i) "banking company" means a company to which the provisions of theBanking Regulation Act, 1949 (10 of 1949) applies and includes any bank or banking institution referred to in Section 5l ofthat Act; (ii) "co-operative bank", "primary agricultural credit sociew" and "primary co-operative agricultural and rural development bank" shall have the meanings respectively assigned to them in the Explanation to sub-section (4) of Section 80-P; (iii) "loan or deposit" means loan or deposit of money; (iv) "specified sum" means any sum of money receivable, rvhether as advance or otherwise, in relation to transfer of an immovable property, whether or not the transfer takes place. Section 27lD of the Act: 271-D. Penalt5r for failure to comply with the provisions of S,ection 269-55:- (l) If a person takes or accepts any loan or deposit or specified sum in contravention of the provisions of Section 269-55, he shall be liable to pay, by way of penalty, a sum equalto the amount of the loan or deposit so taken oraccepted. (2) Any penalty imposable under sub-section (l) shall be imposed by the Joint Commissioner: f'rovided that any penalty under sub-section (l), on or after the lst ctay of April ,2025. shall be imposed by the Assessing Officer." I l. The reassessment order under Section 147 read with Section l44B of the A.ct, dated 15.03.2022 relatable to the assessment year 2017-18 reads as under: ( !
'!i r3 "[n this case, the assessee company f,rled its lncome Tax Return on 4.1 l.2ol7 for the Assessment Yeat 2017-18 declaring income at Rs.8,60,800/- and the same was processed u/1 l 3 (l) of the lncome Tax Act, t961. As per information available in the department, the assessee has deposited cash of Rs' 14,38'000/- in his bank accounts during the period of demonetization. During enquiry proceedings, the asiesst. f"il"d to Frle specifically the source of each of [e cash deposit and has not fumished the details of advances received- As such, the amount' of 'Rs'14'38'000/- remained unexplained and proceedings u/s 147 of the Income Tax Act, l96l were intimatid to assess the cash deposits of Rs.i4,38,000/-, which was deposited during the p9li99 of demonetization. Notice u/s 148 of the Income Tax Act' 196l was issued on 31.03.2021 after obtaining approval of the competent authority.
In response to the notice issued tr/s 148 of the Income Tax Act, 1961, t-he assessee filed its lncome Tax Return on 5'5'2021 a"cia.ing in.o." at Rs.8,60,800/-' Notice,/s 143 (2) of the lncome TaxAct,lg6lwasissuedtotheassesseeon2S'12'202landin ,*p;"'to the notice, the assessee filed the requisite information. The assessee is engaged to operate construction activities' During the Fy 2016-17, ro.ir"" of income of the assessee was residential villas. The information, including the three sheets of cash book for the period l.g.2016 to 31.2.2016, filed by the assessee was examined with reference to the reason re-opening the case and no adverse inference is drawn. Hence, returned income of the assessee is accepted."
The proceedings under Section 27lD of the Act were initiated by the Joint Commissioner on the ground that during the assessment year' the assessee had accepted an amount of Rs.40,00,000/- in cash from its customers on sale of plots/residential house as advance/initial payment' The details of cash received were enumerated in the form of a chart' which showed that such amounts were received from various persons exceeding Rs.20,000/- during the assessment year in violation of Section 26955 of the Act. The assessee took the plea that the assessee had sold its land to various persons who are farmers. They were unable to make the ! i l4 payment in cheque and gave the money in cash. The accountant unknowin;gly collected cash and deposited in the bank. The amount collected liom its customers was below Rs.2 lakhs from every individual. The deposrited amount is in the form of cash receipt for sale of individual plots. Acr:ording to the assessee, under Section 2695T of the Act, a person should not receive an amount of Rs.2 lakhs or more except by way of an accrount payee cheque, bank draft or electronic clearing system through a bank account or any other electronic mode in respect of a single transaction. Therefore, the question of applying Section 26955 and levying the penaltl, under Section 27lD of the Act does not arise. The amounts have been treated as cash receipts and deposited in bank. He made 416:quest to drop the penalty proceedings as it is within the purview of, Section 2695T of the Act 13. [n the light of these facts. it is relevant to refer to the CBDT Circular No.09/DV12016 (departmental view), dated 26.04.2016 on the subject c'f limitation for penalty proceedings under Section 27lD and 27lE of the Act. l-he circular made reference to the decision in the case of Grihalakshmi vision (supra) rendered by the Kerala High Court. The observations made therein have been treated as 'the departmental view' and are extracted hereunder: 1 I i I :j ;: ii ii ii ii ti li liii'i i i ( I
l5 ..
The Hon'ble Kerala High court in the case of Grihalaxmi vision v. Addl. commissione, of In.ome Tax, Range l, Kozhikode (Available in NJRS 2015-LL-0807-4) vide its order dated 8.7.15 in ite Nos.gl & *6 of 2014, observed that "Question to be considered is whether proceedings for levy of penalty' are initiated *ill, ,|rc passing of the order of assessment by the Assgssing Oficer or whetie^uih pro"rrdings-hae commenced with the instance of lhe notice issuei by the Joint Commissioner' From statutory plrorisun, it is cleai that rhe competent authority 1o,le2 pen?lty 'bring the Joint Commissioner- Therefore' gnly the Joint Conimissioner can initiare proceedings for levy of penalty' Srch initiation of proceedings ,oild not have been done by the Assessing officer. Ti;srarcmenlin the ossessment order that the proceedings uider Secrion 271D and E are initiated is inconsequential. On the other hand, if the assessmenl order is taken as the initiation of penalty procLedings, such initiation is by an aytltority who. is 'inro,iprr"nt and tie proceedings thereafter would be proceedings withoit authority who f incompetent and the proceedings thereafter would'be proceedings without iurisdiction. If that be so, the initiarion of the penalty p,iceedings is only with the issuance oJ the notice issied iy the Joint Commissioner to the assessee to which he hasfiled his rePlY;'
The above judgment reflects the "Departmental Yi:t''' Accordingly, the Asslssing Officers (below the rank of Joint Comrnissioner of lncome Tax) may be advised to make a reference to the Range Head, regarding any violation of the provisions of Section 26955 and Sectlon Ziqf of the Act, as the case may be' in the course ofthe assessment proceedings (or any other proceed-ings under the Act). The Assessing Officer, (below the rank of Joint commissioner of lncome Tax) shall not issue the notice in this regard. The Range Head will issue the penalty- notice and shall dilpose/complete lhe proceedings within the limitation prescribed u/s 275(l)(c) of the Act."
A perusal thereof would show that the Joint Commissioner can initiate proceedings for levy of penalty. Such initiation of proceedings should not be done by the assessing officer. The statement in the assessment order that the proceedings under Sections 27lD and271E of the Act initiated are inconsequential. On the other hand, if the assessment order is taken as the initiation of penalty proceedings, such initiation is by )
-t t6 r \ i ,j :] .:i ii rl it jl il'ii iI il an authcrrity who is incornpetent and the proceedings thereafter would be the proceedings rvithout jurisdiction. If that be so, the initiation of the penalty proceedings is only with the issuance of the notice by the Joint commissioner to the assessee to which he ha.s filed his reply. This observalion of the Kerala High court in the case of Grihalakshmi vision (supra), has been adopted as .the departmental view'.
From the discussion made hereinabove, it is apparent that the CBDT Oircular, dated 26.04.2016 issued on the basis of the observations in Grihalakshmi vision (supra) by the Kerala High court is on the subject ,rf limitation for initiation of penalty proceedings under Section 27lD and2TlE of the Act, wherein it has been held that the competent authorit;r to levy penalty is Joint Cornmissioner and not the assessing dfficer. on the other hand, in the case of srinivasa Reddy Reddeppagari (supra), a coordinate Bench of this Court has referred to the case of Jaya Laxmi Rice Milts (supra) and categorically recorded that the Supreme court had concurred with the view taken by the High court trolding that satisfaction must be recorded in the original asS€SSrrlrsot order for the purpose of initiation of penalty proceedings under st:ction 27lE of the Act. Sections 27lE and 27lD of the Act arc in pari ma,teria. when there is a decision of the suprerne court, it is the bounden duty of an adjudicating authority, be it an income tax authority
t7 or any other civil authority or for that matter any court in the country, to comply with the decision of the Supreme Court. The very issue involved in the present writ petition, whether without satisfaction being recorded in the assessment order, penalty can be levied by the Joint Commissioner under Section 27lD of the Act was in question in the case of Srinivasa Reddy Reddeppagari (supra). As such, we do not find any grounds made out by the Revenue to take a different view in the instant case.
Accordingly, the order, dated 19.10.2022, imposing penalty by the second respondent under Section 27lD read with Section 274 of the Act and the appellate order dated 04.06.2025 upholding the same by the first respondent are set aside.
The writ petition is accordingly allowed. There shall be no order as to costs. Miscellaneous applications pending, if any, shall stand closed. A. SREENIVASA REDDY //TRUE SECTION OFFICER
The Commissioner of lncome Tax Faceless Appeal Centre (NFAC)
Assesliienruii Centre, lncome New Delhi. To PSK. GJP Faceless Assessment Government of lndia,
The Joint commissioner of Income Tax, Range s, lncome Tax Department, - Hyderabad,Telangana.
The lncome Tax dfficer, ward 16(3), rncome Tax Department, Hyderabad, Telangana 5. ln9 -seg1eJary, Union of lndia, Ministry of Finance, 166-8 North Block, New Delhi - 110 001
One CC to SRI B.KRISHNA REDDY, Advocate tOpUCI
ONC CC tO SRI K.SUDHAKAR REDDY, SENION SC IIrrbOUrC TAX TOPUC]
Two CD Copies N, I I i I
I HIGH COURT DATED:05/03/2026 ORDER WP.No.24403 of 2025 ALLOWING THE WRIT PETITION WITHOUT COSTS HES 1 31 5 APB 2026 X -t * t:( I \ frL'
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