YERUVA RAYAPPA REDDY vs. Assessment Unit

r, [3447 | HIGH COURT FoR THE STATE oF TELANGANA AT HYDERABAD (Special Original Jurisdiction) MONDAY,THE THIRTIETH DAY OF JUNE TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA WRIT PETITION NO: 18268OF 2025 Between: AND YERUVA RAYAPPA REDDY, S/o. LOURD REDDY YERUVA Aged about 64 y9ap, QcggOqtion Business, Rl/o H No 6- 80 Basuregadi VillageiBasuregadi, Medchal [Vedchal Mandal Rangareddy Dist 50i40j Tela;gana, lnd"ia , Assessment Year 2020- 21 ...PETITIONER '1 . Assessment Unit, National Faceless Assessmenl Centre. lncome Tax Department . lVinistry ..of Finance, Room No. 4O1 , 2nd Floor, E- Ramp, Jawaharlal Nehru Stadium, Delhi - 110 003. 2. The lncome Tax Officer, Ward 15(1), Hyderabadl lT TOWER, AC Guards, - Masab Tank, Hyderabad- 500004 Telangbna S qnig!, 91 lnqia, Represent by Secretary tvlinistry of Finance North Btock, New Delhi- 1 10 001 I ...RESPONDENTS Petition under Article 221 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewrth, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature WRIT OF MANDAIVUS holding that the notice issued (JAO) by 2"d Respondent under section 148 Dated 31 .03.2024 vide DIN No trBA/AST/s/148 _112023-2411063782570(1) for the Assessment year 2O2O- 21 and The consequential order passed by the 1st respondent uls. 147 read with section 1448 of the lncome- tax Act Date of Order 31. 01. 2025, DIN lrBA/AST/s/l4712024-2511072778243(1) for the Assessment year 2o2o- 21 , as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart from violation of Articles ta, 19 (t Xg) and 265 of constitution of lndia apart from being violative of provisions of section 'l4BA and sectron 149 of the Act and

also contrary to the circular issued by cBDT and provrsions of section '151A of the Act, and consequently set aside the order passed by 1st Respondent u/s 147 read with section '1 448 of the lncome- tax Act Date of Order 31 01 2025' DIN ITBA/AST/S/1 4 7 t2O24-251 1 07277 8243(1) for the Assessment Y ear 2020-21 and all consequential proceedings pursuant there to lA NO: 1 OF 2025 Petition under section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition' the High Court may be pleased to stay all further proceedings, including any recovery, pursuant to the order passed by the l.tRespondent u/s. 147 read with section 1448 of the lncome- tax Act Date of order 31. 01. 2025, DIN ITBA/AST/S/147t2024-2511072778243(1) for the Assessment Year 2020- 2'l and stay of Demand notice under section 156 Dated 31 01. 2025 vtde DIN No ITBA/AST/S/1 56t2024-251107277838O(1) for the Assessment Y ear 2020-21 Counsel for the Petitioner: SRl. THANNERU CHAITANYA KUMAR Counsel for the Respondent Nos. 1&2: SRI K' SUDHAKAR REDDY SENIOR SC FOR Ms. BOKARO SAPNA REDDY, SC Counsel for the Respondent No.3: SRI GADI PRAVEEN KUMAR' DY. SOLICITOR GENERAL OF lNplA The Court made the following: ORDER

THB HONOURABLE SRI JUSI'ICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSTNG RAO NANDTKONDA WRIT PETITION No.18268 of 2025 ORDER, (per Hon ble Sri Justice Nur.ting Ruo Nurulikonda) Heard Mr.T.Chaitanya Kurlar, leamed counsel lor the petitioner and Mr.K.Sudhakar Reddy, leamcd Senior Standing Counsel for the [ncome Tax Departrnent appearing fbr the respondents. Perused the record. 2. This is a writ petition where the proceedings are either challenged to the notices which were issued under Section 148A and 148 of the Income Tax Act. 196l (for shorl 'the Act') or the assessment orders those have bcen passed under Section 147 of the Act which have been assailed. 3. This writ petition is being taken up today only on one of the grounds, that the notices issued under Section l48A ol thc Act and the subsequent initiation ofproceedings under Section 148 of the Act by the jurisdictional Assessing Officer, whereas in tenns of the amendment that was brought to the lncome Tax Act by way of Finance Act, 2021 w.e.t-., 0l .04.2021 onwards, proceedings

2 under Section l48A of the Act as also under Section 148 of the Act ought to have also been issued and proceeded in a f-aceless lrlannef. 4. Tl.re contcntion of the petitionel is that the issue of proccedings being in violation of the Finance Act, 202 1 i.e., the irnpLrgned notices under Section l48A and Section 148 of the Act not beinq issucd in a t'aceless manner, have already been dealt with and dccided br this Courl in the case ol KANKANALA RAVINDRA REDDY vs. INCOME-TAX OFFICEIIT decided on 14.09.2023 whereby a batch of writ petitions were allowed and the proceedings initiated under Scction l48A as also under Section 148 of thc Act nere held to be bad with cousequential rclict's on the ground olit being in violation of the provisions of Section l5lA of the Act read rvith Notification 1812022 dated 29.01.2022. 'l'he said judgnrent passed by this Courl has also been subsequently tbllowed ir-r a largc rtumbcr of writ petitions which were allowed on sirnilar Ie t'nt s I(l0li) I56 ta\nnnn.com 178 ('l'elangana)l

3 5. Down the line, we flnd that the sante issue has also been decided against the Revenue by various High Courts i.e., b1 the Bombay Fligh Court in rhe case ot. HEXAWARE, TECHNOLOGTES LTD., vs. ASSTSTANT COMMISSTONER OF INCOME TAX & OTHERST, Gauhari High Court in rhe case of RAM NARAYAN SAH vs. UNION OF INDIAT, punjab and Flaryana High Coun in lhe casc of JATINDER SINGH BANGU vs. UNION OF INDIAI, and Telangana High Court in the case of SRI VENKATARAMANA REDDY PATLOOLA vs. DEPUTY COMMISSIONER OF INCOME TAX5 wher.e rhe issue was in respect of international taxation, Bornbay High Court in the case of ABHIN ANILKUMAR SHAH vs. INCOME TAx OFFICER, INl'ERNATIONAL TAXATION;,which is again on inremational taxation and central circle, Fligh courr of Flimachal pradesh in the case of GOVIND SINGH vs. INCOME TAX OFFICERT, Ciujarat High Courr in the case ol MANSUKHBHAI t 7zot.+1464 ITR 430 (Bom) ' [(2024) 156 raxmann.com 478 (Cauhati)] i:,1,.*, tt raxrnann.corn il5 (puniah & Harluna)l Jlr,l+) lQ raxrnann.corn 4ll { I-clanganatl '1202+) 166 raxrnann.conr 679 (Bornbay)l '12021) 165 taxmann.corn I l3 (Himachai t,radcstr)l

4 DAHYABUAI RADADIYA vs' INCOME TAX OFFICER' WARD 3(3)(5)8, Jharkand High Court in the case ol SHYANI StTNDAII SAW vs' UNION OF INDIAe' Rajasthan lligh CoLrL't irt thc case ol SIIAIIDA DEVI CHHAJER vs' INCOMB TAX OFFICER & ANOTHER and batch of writ petitionsro whiclr stood decidcd on 19 03 2024' Similar views have also been taken b1 the l)ir ision Bcnch ol Calcutta High Court in the case of GIITDHAR GOPAL DALMIA vs' UNION OF INDIA & ORS (M.A.l l6c)0 oi202l), dccided on25'09'2024' (t. E.r'crl tllor'rgh thc same issue having been decided by a lalge numbcr ol I Iigh Coutls, we are still confronted with large trling ol ideutical nlllrtel's on daily basis ranging between 5 to 10 rvrit petitiorrs. [.trat upon the instructions being 'o']'ht l-om the Depar.trr.rent. they have been ta[:ing a solitary ground that the decisiorr of thc Bombal High Court in the case of Hexuwure Tachtrologics Lt(t', (2 supla) as also the one rvhich has bcen clecided by this Court in the case of Kanakalo Ravindru Redd'v ,..J, *202+ sc:c onL.ine Guj 4012 ' l0l5 SC C Onl.irrc 'lhar 287 '"Jloll : RJ-JI):198+-DBl I

5 (l supra) has been subjected to challenge in a Special Leave Petition i.e., SLp No.3574 of 2024 befor.e the Hon,ble Supreme Court and the Hon,ble Supreme Court is seized of the rnatter. In addition, there are about 1200 SLps also filed arising out of the sarre rssue being decided by various High Courts. l. 'fo a query being put to the learned counsel fbr the Revenue, thev have categorically accepted the fact that there is no interim order granled by the Hon,ble Supreme Courl in any of these nrat[ers pending befbr.e it. Meanwhile, fiesh writ petitions ol_ icJcntical natLrre are being piled up before this Bench on daily basis and the penclency is getting incr.eased on matter which otherwise has already been dealt and decided by this very High Court itsell. 8. On the one hand, even though the order of this bourt that ivas passed as early as on 14.09.2023 and more 16 months havc lap-sgd, 1111 date, we do not tind any remedial steps having been taken by the Income Tax Deparlrnent to take appropriate steps to either hold back issuance of notice under Section l4gA and under Secrion I4g of the Acr by the jurisdictional Assessing Oflficer. rather. thc aurhorities concemed in the [eeth ol. series of dccisions

6 by atl the major High Courts in lndia are continuouslY still initiating proceedings under Section l48A of the Act and also initiating procecdings under Section 148 of the Act itr contraventiou to the ar-ncndments brougl-rt into the Income Tax Act pursuant to the Irinance Act' 2020 as also the Finance Act 2021' 9. Upon a c1r-relv bcing put as to whY can't this rvrit petition be disposed o['in thc tecth ol the decision rendered by this Coutt irr the case ctl Kunukoln Ravittdra Reddy (l supra)' leamed Standing Counsel lbr thc lncornc 'fax Departrnent contends that those would unnecessarily br-rldeu thc I ncou:e Tax Department whel'e the'v would be lcquired to file equal number of SI-Ps before the Hon'ble SttPretne Court and i'. '^.or-rid be lurlher burdening the exchequer o1- the l-inion ol lndia \ It was also the contentiotl ol the learned Standing Coutrsel that no l!'eiudice would he caused to the in case if this writ petition is kept pending interest of the PetttLoners titl tl-re finalizatiorr ol the SLPs pending before the Hon'blc Supreme Clourt and tlie tact that the petitioner is already enjoying tr.re be'cfit of i'tcri'r protection. i.,ronetheless, on the earlier query of this Court as to wh)' the It.tcot.ne Tax Department have not come out $,ith a lllechanistrl to isstte app|opriate instructiot-ts or to take ) I

7 appropflate steps in ensuring that proceedings under Section I4gA ol the Act as also the assessment orders under Section l4g of the .\cr are kept in a hold in the light of the decisions dedcidecl by the various l{igh Courts, it was submitted by the lear.ned Standing counsel rhat the said steps can only be taken at the revel of GBDT. as any such steps would have to be taken pan India and cannot be Iirnircd ro ar.ry of these jurisdictional High Courts. I0. As a r.esult of which, what we are facing is steep itrcrease ol litigarion day in and day out even though various orders have been passc'cl bv this High Court allowing writ petitions on the very same issuc. 'fhe Income Tax author.ities concemed are still even now in 1025 also initiating p.oceedings in contravention to the provisions o1'Sc.crion I5lA olthc Act and as a result by now, mJre than 600 to 700 petitions have been alreacly got piled up beibre this High Court on an issue which otherwise stands squarely covered by the jrrdsrnent of this Court in the case of Konakolo Ravindro Reddy (l supra). What is also surprising is the fact thatthough while allor,r,,ir.rg the writ petitions in the case of Kunakals Ravinclra Redd.1: (l supra), the Division Bench while reserving the r-ight of the Revenrre, has also protected the interest of. the petitioners

8 insofar as the tiber.ty which rvas granted to the Revenue fbr initiating fiesh proceedings strictly in accotdance with the amended provisions ol tl.re Act, as arleuded by the Finance Act' 2020 and the Finance Act, 2021 ' -l'he pctitioner assessee would be entitled to challenge or raise the other legal objections if the Revenue initiates lresh proceedirrgs' 'l'hc Departnlent has urade no endeavour in availing the said libe rt1 that ir as re scrved tbr the Revenue On the contrary, they lrave bcen stitl sticking on to lhe staLrd' which this High Court as well as rl1arly othcr Lligti Courts ah'eady held to be bad. ll. It apPears that bccattse of th-e alblesaid liberty that this High Court had granted pernlitting ihe Revetluc for initiating fresh proceedings as a onc-tillle lncaslll'e in a laceless lnanner' the Income Tax Deparlrnent wallts to take advantage of the same by protracting these procecdines \'r hich rvould cnable them to meet the limitation that would othe rs'is': cotne in tl-re way Likewise' if the u,rit petition is kcpt pendirrg fbt a considerable long period of time and finally at a later stage if the []on'ble Supleme Couft confirtns the decision takcn by this tligh Coutt as also by the othel High Cor-rrts in which the SLPs are still pending' the Incotle -fax

9 Deparlment u,ould ge1 the advantage of the liberty that is otherwise protected in fhvour of the Revenue for initiation of fresh proceedi'gs rl'on'r the disposal ot'these matters at a much later stage which would be advantageous and beneficial to the Revenue and would be equally disadvantageous and detrimental so far as interest of the assesses are concerned. As a consequence, the Incorne Tax Depa.t.rent gers an extended period of tirne for initiation of rresh ploceedings 12. fhe alar.nring tr.end oldocket explosion in this Court, despite thc clear prece<1enr set, ir-t Konakrtla Rovindra Redety (l supra), is a matter ol- grave concern. The Incorne Tax Department,s persistent initiatio, ol liesh pr.ccedings, disregarding the established judicial pronounccnreu ts, has lcd to an unprecedented .u.g" tin litigation with over 600-700 pcririons piling up on the same issue. r-his deliberate approach r,.,t o.ry undermines the principre ofjudicial precede,r but also st.ai,s the jucriciar resources unnecessariry. I.he Depart,'rent's strate-qy of arvaiting the Supre,re court,s decision on pending SLps rvhilc continuing to initiate fresh proceedings appears to be a calculatccl move to buy tipe and circumvent lirnitation periods, r.a rher rhan adhering to the established Iegal

10 position. Such conduct raises serious questions about lhe adrninistrative efficiency and the fespect tbr ]udicial pronouncclnents, parlicular'ly rvhcn this Court has already provided a balanced approach by preserving both thc Revcnue's rights and assesses interests. 13. Another aspect which needs to be considered is that in lact it sr_rould rravc been rearized by the I.courc [-ax L)epartnre.t itsell a,d should have found out via uredia in erlsuring that proceedings under Sections i48-A and 148 shoulcl not have heen issued in a faceless manner, at least till the H'.ln''blc Suplemc (]ourt dccide the twelve hr'rndred (1200) odd Sl-Ps shich it is elready seized of or' at least the Income Tax Depaflrn;nl sitottld havc lound out solne remedial steps to ensure that ivltcrc.''et the atrthorilies intcnd to initiate ploceedings under Sectiorrs 14t3-A and I 48' otl.rer tl.ran in a faceless manner, the procecclings shoulcl have been def-ened without precipitating the mattel furthcl irrtirnating thc assessee that they shall initiate appropriatc procecdings onll alter the SLI"s ate decided by the Hon'ble Supleme Court ou the verv satne issue' Tl-ris again, the Incotne'fax L)epartLneut' has not bcen able to give a cotlvitlcing leply, exccpt fbr the lact that such a clecision if at all

11 has to be taken, has to be taken fbr the whole of India, and which otherwise has to be bv rvay of- a policy decision and that too at the level of Centr.al Iloard o1' Direct Taxes. Though the leamed standing counscl fbr the l.corne Tax Department contended that the Dethi High Court dismissed a writ petition of similar nature, on the one hand w,hen thc l{igh Court is struggling to reduce its pendency, such norices u,'h ich are under challenge in this writ petition are fbrcing the asscssee to knock the doors of this High cou.t resulting in fili.g of hundreds of ,ew writ petitions which in the long run not only al1-ects the disposal of the writ petitions but also consumes substantial lirne of the Bench in hearing these matters again and again on daily basis. Admittedly, in spite of the rnatter betbre the Hon'blc Srrpreme Court having ben taken on many occasions, the IJon.ble Sirpr.eme Court which is seized of the matter has been rcluctant in qranting any interim protection to the Income fax Depart.ntent. yet, the authorities concemed at the State level are not read-v to accept the verclict passed by a majority of Iligh Courts ol dill'erent States on the same issue; and to make things further r,vor.se. the Incorne Tax Department IS showing audacity by issui,g,.tices conti.uously u,der Sections l4g_A and

12 148 through the jurisdictional Assessing Offlcer uhclcas it ought to have been only in the faceless manner 14. In the case ol BANK OF INDIA vs' '{SSISTANT COMMISSIONBR, INCOME TAXTT' orr au issue rvhether it rvas justifiable on the part of the lncome Tax Departmcnt in not following an order passed by thc adjudicating alrthorit) only on thc ground that the appeals are pending' thc t)irisiorr UcLrch of thc High Courl of Bombay held at paragraph No'25 as undeL' l'iz'' : "25. Mr. Paridwalla has rightly drawn out attent on to the decision of this Court in Commissioner of lncome Tax vs Smt' Godavaridevi Sarafl2 as also the recent decision of the co- ordinate Bench of this Court in Samp Furniture (P) Ltd' v' lTOrl of which one of us (Justice G S Kulkarni) was a member' wherein the Court categorically observed that the Revenue having not "accepted" the judgment of the High Court would not mehn that till the same is set aside in a mannei'knorrn to law it would loose lts binding force. Referring to the decision of the Supreme Court in Union of lndia vs. Kamlakshi Finance Corporation Ltd'1o' the Court observed that the approach of the officials of Revenue of treating decisions being "not acceptable" was criticized by the Supreme Court. ln such decision' following are tne relevant observattons made by the Supreme Court' " 11zoz:1 170 taxtrann.corn 422 (Bomba) )l '' 1t9281 113 ITII 589 (Bornbal') 't iZOz+] 165 taxrrann.com 58l/300'hrtuart -152 (llombal') " 1t9e:1 taxlnann.corll 16155 EI-1 4li (SC) )r./

13 "6. Sri Reddy is perhaps right in saying that the officers were not actuated by any mala fides in passing the tmpugned orders They perhaps genuinely felt that the claim of the assessee was not tenable and that, if it was accepted, the Revenue would suffer. But what Sri Reddy overlooks is that we are not concerned here with the correctness or otherwise of their conclusion or of any factual malafides but with the fact that the officers, in reaching in their conclusion, by_passed two appellate orders in regard to the same issue which were placed before them, one of the Coltector (Appeals) and the other of the Tribunal The High Court has, in our view, rightly criticized this conduct of the Assistant Collectors and the harassment to the assessee caused by the failure of these officers to give effect to the orders of authorities higher to them in the appellate hierarchy. lt cannot be loo vehemen y emphasized that jt is of utmost importance that, in disposing of the quasrudicial issues before them. revenue officers are bound by the decisions of the appellate authorities. The order of the Appellte Collector is binding on tlhe Assistant Collectors working wrthin his jurisdiction and the order of the Tribunal is binding upon the Assistant Collectors and the Appellate Collectors who function under the jurisdiction of the Tribunal. The principles of judicial discipline require that the orders of the higher appellate authorittes should be followed unreservedly by the subordinate authorities The mere fact that the order of the appellate authority is not ,,acceptable,,to the department - in itself an objectionable phrase _ and is the subject matter of an appeal can furnish no ground for not following it unless its operation has been suspended by a competent court. lf this healthy

L4 rule is not followed, the result will only be undue harassment to assesses and chaos in administration of tax laws 12. We have dealt with thrs aspect at some length' because it has been suggested by the learned Addrtional Solicitor General that the observations made by the High Court, have been harsh on the officers. lt is clear that the observations of the Hrgh Court. seemingly vehement' and apparently unpalatable to the Revenue, are only intended to curb a tendency in revenue matters which' if allowed to become widespread, could result in considerable harassment to the assesses-public without any benefit to the Revenue. We would like to say thal the department should take tiiese obsen'/atlons in the proper spirit. The observaticns of the High Court should be kept in mind in future and the utmost regard should be paid by the adiudicating authoritres and the appellate authorities to the requirements of juqicial discipline and the need for giving effect to the orders of the higher appellate authorities which are brnding on them." L 5. What is worrying this Bench more is llrc lact tltat att endeavour is being made whole heartedly to enslt[e noI to gclleratc fLrrlher titigation on issues which have been laid to rest b)' a larqe number of t{igh Courts all of whom have taken a consistent stand that the action of the Income Tax Departrnent bcing Violativc of the --\

15 I''inance Act,2020 and Finance Aot, 202 l. Now, in order to protect the interest of the Revenue as atso that orthe assessee, it would be trite at this juncture, if we dispose ol- the writ petition with an obscrvation/direction that the disposal of the instant writ pctition in terms of the judgment rendered by rhis High Court in the case of Kukanala Ravindra Reddy (l supra) shall however be subject to the outcome of the SLps wi-ricli r,r,er.c tilcd by the Income Tax Deparlment and which is pending consideration bcforc the Hon,ble Supreme Cour1. 16. In the given f-acts and circu rnstanc c.s, this Bench is of the considered opinion that unless and until we do not tirnely dispose of matters which are squarely covered by the decision of tr.ris court and which stands fortitied by the decisio,s of the vlr,ious other High Courts on the very same issue, the pendency of this High court would further be burdened whicl.r or.rre.i.vise can be decided and disposed of as a covered matter. 17. So fdr as the ir-rterest of the Rcvcnue is concerncd, we are of the considered opinion that the interest of the Revenue has already been considered and protected, as has been obscrr.,ed in paragraplis

16 36, 37 and 38 of the order which, for ready reference, is reprodr.rced hcreundet': 36. For all the aforesaid reasons, the lmpugned notices issued and the proceedings drawn by the respondent- Department is neither tenable' noT sustainable The notices so issued and the procedure adopted being per se illegal, deserves to be and are accordingly set aside/quashed. As a consequence, all the impugned orders getting quashed, the consequential orders passed by the respondenlDepartment pursuant to the notices issued under Section 147 and 148 would also get quashed and it is ordered accordingly The reason we are quashing the consequential order is on the prtncrples that when the rnitiation of the proceedings itself was procedurally wrong' the st-ibsequent orders aiso gets nullified automaticallY. 37. The preliminary objection raised by the petitioner rs sustained and all these writ petitions stands allowed on this very jurisdictional issue. Since the impugned notices and orders are getting quashed on the point cf jurisdiction, we are not inclined to proceed furlher and decide the other issues raised by the petitioner which stands reserved to be raised and contended in an appropriate Proceedings. 38. Since the Hon'ble Supreme Court had' in the case of Ashish Agarwal, supra, as a one{ime measure exercising the powers under Article 142 of the Constitution of lndia, permitted the Revenue to proceed under the substituted provisions, and this Court allowing the petitions only on the procedural flaw, the right

17 conferred on the Revenue would remain reserved to proceed further if they so want from the stage of the order of the Agarwal, supra Supreme Court in the case of Ashish t8. We would only fufther like to make observations that since we are inclined to dispose of the instant writ petition, conscious of the fact that the earlier order of this High Courr in the case of Kanakala Ravindra Retlet), (l supra) is sub.jected ro cl.rallenge befbre the Hon,ble Supreme Court in SI_p No.j574 ol 1024. plet-erred by the Income Tax Deparlment, \{,e rnake it clear. that allorving of the instant writ petition is sLrbjecr to ourcornc of.the aloresaid sLp preferred by the R.evenue against the decision or this I{igh Court in the case of Kanskola Rovirtrlrrt Reddy (t supra). l-his, in other words, would mearr that either.of the pqrtics, ilthey so want, rnay move an appropriate petition seeking r.cvival ol this writ petition in the tight of the decision of the Hon.ble Suprer.ne Couft in the pending SLp on the very sarne issuc. 19. Accordingly, the instant writ pelition srands allorvcd ) f-avour of the assessee so far as the issue ol jLrr.isdiction ln IS concerned. As a consequence, the impugned notice un<.ler challcnge under Sections l4g_A and l4g stands ser asideiclLrashcd )

1u To, The consequential orders, if any' also stand set aside/quashed in siniilar terms as have beetr passed by this High Courl in the case ot Kanknnrtlu Rat'indra Rerlrly ( t supra)' There shall be no order as to costs. Conscqucntly. rniscellaneous petitions pending' il any' shall stand closed SD/. M. OSMAN ALI BAIG ASS ST NT REGISTRA* \ //TRUE COPY' S CTION OFFICER 1. Assessment Unit, National Faceless Assess Department, lVinistry of Finance, Room No. Jawaharlal Nehru Stadium, Delhi - 1 10 003. 2. The lncome Tax Offrcer, Ward 15(1), Hyderabad/ lT TOWER, AC Guards, I\4asab Tank, l-lyderabad- 500004 Telangana 3. The Secretary,'Union of lndia, IVinistryof Finance North Block, New Delhi- 110 001 4. One CC to SRl. THANNERU CHAITANYA KUMAR Advocate IOPUCI 5 One CC to Ir/S BOKARO SAPNA REDDY , SC FOR STATE TAX [OPUCI 6 One CC to SRI GADI PRAVEEN KUMAR, DY SOLICITOR GENERAL OF rNDrA [OPUC] 7. Two CD Copies 4 Centre, lncome Tax 2nd Floor, E- Ramp, bl BIU TKS \

HIGH COURT DATED:3010612025 1t1E S147 o o \ l' 5E 16 P rffi \". \ lS r:,a1q;H.-:- ORDER WP.No.18268 of 2025 ALLOWING THE WRIT PETITION WITHOUT COSTS & rl