Suvarna Maddi vs. Income Tax OfficerWard9(1)

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WP/27416/2024HC TelanganaHBHC01053270202425 April 2025Bench: P.SAM KOSHY,NARSING RAO NANDIKONDA4 pages
AI SummaryRemanded

What did the High Court hold?

The High Court allowed I.A. No. 1 of 2026, thereby recalling its earlier order dated April 25, 2025, passed in Writ Petition No. 27416 of 2024. The Court reasoned that the Supreme Court, in its order dated April 10, 2026, had remitted all matters related to faceless proceedings to the respective High Courts and permitted petitioners to question the constitutional validity of Section 147-A of the Income Tax Act, 1961. Given that the High Court had previously granted liberty to move for revival subject to the Supreme Court's outcome, and the Supreme Court has now remitted such matters, a strong case for recalling the previous order has been made out. The operative direction is that the earlier order stands recalled, paving the way for fresh adjudication in light of the Supreme Court's directive.

What were the facts?

The Income Tax Department (Petitioners/Respondents) filed an interlocutory application (I.A. No. 1 of 2026) before the High Court for the State of Telangana at Hyderabad, seeking to recall an order dated April 25, 2025, passed in Writ Petition No. 27416 of 2024. The original writ petition was filed by Suvarna Maddi (Respondent/Writ Petitioner). The Department's application is based on a subsequent order dated April 10, 2026, passed by the Supreme Court in a batch of cases concerning faceless proceedings. The Supreme Court had remitted these matters to the respective High Courts, allowing petitioners to question the constitutional validity of Section 147-A of the Income Tax Act, 1961. The High Court had previously granted liberty to the parties to move for revival of the writ petition, subject to the outcome of the Supreme Court matters.

What were the issues?

1. Whether the order dated April 25, 2025, passed in Writ Petition No. 27416 of 2024 should be recalled and the writ petition revived for fresh adjudication, in light of the Supreme Court's order dated April 10, 2026, concerning faceless proceedings and the constitutional validity of Section 147-A of the Income Tax Act, 1961? Assessee (Suvarna Maddi) Contentions: The judgment does not record any specific contentions made by the assessee in this interlocutory application. However, the context implies the assessee would support the recall of the earlier order to allow for fresh adjudication based on the Supreme Court's directive. Revenue (Income Tax Department) Contentions: The Revenue contended that the Supreme Court's order dated April 10, 2026, which remitted matters concerning faceless proceedings to the High Courts and permitted challenges to Section 147-A of the Income Tax Act, 1961, necessitates the recalling of the earlier High Court order. They relied on the Supreme Court's decision in Income Tax Officer, Chandigarh & Ors. v. Tej Partap Singh.

Which sections of the Income-tax Act were involved?

Section 147-A

AI-generated summary — verify with the full judgment below

13447 | IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD WEDNESDAY, THE TWELFTH DAY OF AUGUST TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA I.A.N o.1 0F 2026 IN WRIT PETITI ON NO: 27416 0F 2024 Between: 1. lncome Tax Officer Ward 9 (1), Hyderabad, l T Towers' A C' Guards' Masab Tank, Hyderabad-500004. Z. Tfre pririclpal Chief Commissioner of lncome Tax AP and TS' 10h Floor' C- Block, l.T. Towers, 10-2-3, A.C. Guards, Hyderabad-500004' S. ine Assessment Unit, lncome Tax Department' National, Faceless Assessment Centre, Delhi, Ivlinistry 6f Finance, Room No' 4O1' 2'- l-loor' E- Ramp, Jawaharlal Nehru Stadium, Delhi-1 10003' .,.PETITIONERS/RESPONDENTS AND l.SuvarnaMaddi,W/oMaddiRamchandraReddy,Agedabout.69.years' Otcupation. Agriculturist, Plot'No 54, H No 5-4-236' Kamala Nagar' Vanasathlipurann, N"al. BalaBarathi High School' Ranga Reddy' Telangana- 500070. ...RESPONDENT/WRIT PETITIONER PetitionunderSection,l5lCPCprayingthatinthecircumstancesstatedin the affidavit filed in support of the petition, the High Court may be pleased to revive/recalltheorderdated25.04.2025passedinW.P.No'2741612024forfresh adjudication in light of the Order dated 10 04 2026 passed by the Hon'ble Supreme court in lncome Tax Officer, ward 2(1), chandigarh & ors. v Tej Partap Singh This petition coming on for hearing, upon perusing the petition and Memorandum of Grounds filed in the support thereof and upon reading the Order I

2 daled 25.04.2025 in WP No.27416 OF 2024 and upon hearing the arguments of SRI KAMASANI SUDHAKAR REDDY, SENIOR SC FOR INCOME TAX, appearlng on behalf of the Petitioners and SRI DUNDU SASHANK MANMOHAN, appearing on behalf of the Respondent. The Court made the following: ORDER l.A.No.l of 2026 is filed by the respondenUlncome Tax Department seeking for the recalling the order, dated 25.04.2025, in WPNo.27416 of 2024 in terms of recent decision of the Hon'ble Supreme Court il, the faceless batch which was decided on 10.04.2026, whereby the matters were all remitted to the respective High Couris, permitting the petitioners therein to question the constitutional validity of the provision under Section 147-4 of lncome Tax Act, 1961. This Court while disposing of the instant writ petition at the first instant, had granted the liberty b the either of the padies to mov'e proper application for revival, subject to the outcome of the matters pending before the Hon'ble Supreme Court pertaining to the faceless proceedings. Given the fact that the Hon'ble Supreme Coud has itself remifted all those matters pending before the Hon'ble Supreme Court to the respective High Coutts. We are of the considered opinion that a strong case for recalling the order dated 25.04.2025 has also been made out. Accordingly, lA No.l of 2026 stands allowed and the earlier order stands recalled. SD/. AHMED ABDULLAH KHAN ASSISTANT REGISTRAR //TRUE COPY// \ $ TION OFFICER To, '1 . lncome Tax Officer Ward 9 (1), Hyderabad, l.T. Towers A.C. Guards, Masab Tank, Hyderabad-500004. 2. The Principal Chief Commissioner of lncome Tax AP a1d TS, 'lOth Floor, C- Btock, l.T Towers, 10-2-3, A.C. Guards, Hyderabad-500004. 3. The Assessment Unit, lncome Tax Department, National Faceless Assessment Centre, Delhi, Ministry of Finance, Room Nlo. 401 , 2nd Floor, E- Ramp, Jawaharlal Nehru Stadium, Delhi-1 10003.

J 4. Suvarna Maddi, Wo Maddi Ramchandra Reddy, Occupation. Agriculturist, Plot.No 54, H.No.5-4-236, Kamala Nagar, Vanasathlipurann, Near BalaBarathi High School, Ranga Reddy, Telangana-500070. 5. The Section officer writ Division Bench section High court for the state of Telangana, Hyderabad 6. The Section Officer, Posting Section, High Court for the State of Telangana, at Hyderabad. 7. One CC to SRI KAMASANI SUDHAKAR REDDY, SENIOR SC FOR TNCOME TAXIOPUCI 8. One CC to SRl. DUNDU SASHANK MANTMOHAN Advocate IOPUC] 9. Two CD Copies BM TKS AK

4 HIGH COURT DATED: 1210812026 ORDER t.A.NO.1 0F 2026 IN WRIT PETITION NO: 27416OF 2024 IA IS ALLOWED TWO DRAFTS Lrsr oN 27.08.2026 oR 1 kiE 5--r4 /1 5e,3 31 AUE t!?i zo *^ -$ 'iia+.. *{) \it-c."so, -tt9-:;/ -_r ^Jr >olnl*

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