Mohammed v. Secretary Ministry of Finan@ North Bbck, New

Judgment

#3. A,o. 401 H*r,,#:ga"Lil No.6( Hisi,?'r,a8,i, Represent by Secretary Ministry of Finan@ North Bbck, New Petition under Article 226 of the Constitution of lndia .RESPONDENTS appropriate stated in the atfidavit filed therewilh, the High Court may be one in notice issued (JAO) 6y 2,a writ, order or direction more particularly Praying that in the holding that the OF MAND{MUS circumstances pleased to ,ssue an the nature of WRIT 2 -'l Respondent under section 148 Dated. 21 .04.2022 vide DIN No- - 12022-231 1042806632(1 ) for the Assessment Year 201 8-1 9 ITBA/AST/S/1 48 and the consequential order passed by the 1st respondent uls. 147 r.w.s '144 read with section 144Bof the lncome-tax Act Date of Order 11.03.2024, DlN. ITBA/AST/S/1 a7t2}23-24110623517tb(1) for the Assessment Year 2018-1s, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart from violation of Articles 14, 19 (1Xg) and 265 of cpnstitution of lndia apart from being violative of provisions of seclion 148A and section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section 151A of the Act, and corrsequently set aside the order passed bY 1st ResPondent u/s' 147 r.w.s 144 read with section 1448 of the lncome-tax Act Date of Order lTBArASTrsrl 47 t 2023-211 1 062351746(1) for the Assessment proceedings pu rsuant thereto'

11.03.2024, DtN' Year 2018- 19 and all conseguential praYing that in the circumstances stated rt may be Pt6ased to passed the High Cou to the order Petition under Section 151 CPC in the affidavit filerd in luP-Port'of the Petition' staY all further Proceedings' by the 1st ResPondent u/s' tax Act Date of Order 't 1'03 for the Assessmerrt Dated. 1 1.Og-2O24 vide DIN No' , Pursuant including any reePvery 147 r.w-s 144 read with section 144Bof the lncome- s1746(1) .2024, DlN. ffBNAST/S/ 14712023-24110623 nd notice under sectio n 156 for the Year 2O1 8- 19and staY ol Dema 15612023-2411062351855(1) disposal of the writ Petition' Year 2018- 19' Pending Counsel for the P'etitioner: for the for the R,esPondent THANNERU No.l & 2: ils' J : SliT B' Sr. SG No'3 GHATANYA KUilIAR Sr. SG FOR lT YADAv, GOVT. , Son 406, D. .'+:'iiif3:$;xo3,.$ R'$: 3 D 1. Assessment Unit, lncome Tax !99m No.4O1, 2ndFloor, E-Ramp, oo3. National e-Assessrnent Center, Nehru Stadium, New Delhi-l 10

#2. 1 rclT 1, Silnature Towers, Telangana- 500084 Sy No 6(P),

#3. Commissioner of lnoome ta:r (NFAC), C,-B lock, 4th Ftoor, S (Appeals), National Faceless Aopeal Centre P M CMc Centre, New Delhi - t1d00l. 4

#5. lncome Tax, Andhra Pradesh and No.922, 9th Floor, B Block, lTTovvers, of Finance, Govemment of lndia, New Delhi- 110 0O1. Petition under Article 226 ot lhe constitt{ion of lndia prayrng that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ of Mandamus or any other appropriate writ, order or direction - (a) declaring 1961, dated 2O2O-21 as procedure la consequenfly. the notice under Notice under Section 14g of the lncome Tax Act, 31 .O1.2O24, passed by 2nd Respondent for the assessment year being without jurisdiction a nd contrary to faceless assessment id down in Section 1448 of the lncome Tax Act 1961 and (b) to set-aside the subsequent proceedings in order under Section 147 dated 08.03.2025 issued by the 1st Respondent and along with all consequential proceedings thereto for the assessment yeat ZO2O_21 as being without Jurisdiction, arbitrary, illegal, bad in law, apart from being violalive of Artictes 14, 19(i[g) and 265 of the Constitution of lndia and contrary to Section 1 44B of the lncome Tax Act in the interests of justice. assessment procedure laid down in and consequentty set_aside the same facelgss 1961, 1 petition under Secl in the arridavit r,'"d,, ";p";';,ffii, fr:;5:; ffiHJ:H:*,: grant stay of art further proceedings, including any recovery, incruding stay on 4 any coercive recovery or further appeal prbc€edings, pursuant to the impugned - notice under Section 148 dated 31:O3.2024 issued by the 2nd Respondent' under section 147 read with sections 144 and144B of the lncome Tax Act, 1961 for the assessment year 2O20-21 subsequent proceedings in order under Section 147 dated 08.03.2025 issued ty the 1st Respondent, pending disposal of the Writ Petition ati otherwise the Petitioner will be put to severe loss and hardship. Gounsel forthe Petitioner: ills. AKRUTI AGARWAL t?m 1to4: Ms. BOKARO SAPNA Sr. SG FOR lT Respondent No.5: SRI N.BHUJANGA RAO' DEPUW SOLICITOR GENERIALOF INDIA I I rs, Occ.. Business. --- Nagar, Nalgonda Between: F/o 19-907/8, District - 508 20 7., D ' IHJ,ffi; Jft1'ffiHtl3,x* -5@ 1, Telangana 1,

#2. The 9th Ftoor' Room No - 500 004, 1-elangana. f :r'Jffi [:;5t.1ic"BtJ;i'Ilrl'#"'f,'d lncome Tax Office, Near Rail' 'ffiHlfit'|}$#]rn?Et Petition unrJer Article 226 of the Constitution of lndia praying that in the circumstances stirted in the affidavit filed therewith' the High Court may be pleased to issue a Writ of Mandarnus or any other appropriate Writ' Order or Direction, dectaring that' a. the order passed u/s 148A(d) of the lncome Tax Act' 1961 ' bearing DIN and t'lotice t'to'tfAA/AST/F/148A/2024-2511064443865(1)' 1st Respondent dated' 29'04'2024' by the i 5 b. the notice issued u/s 1,,18 of the lncome Tax Act, 1961, dated. n.M.2O24, bearing DIN and Notice l.lo.lTBA/ASTlSll4E_112O24-2511o64444194(1), by the 1st Respondent for the Assessment Year 2017 - 18, as arbitrary, illegal, bad in law, void-ab-initio, violative of the principbs of natural justice, apart from being violative of Articles 1 a' 19(1 xg) and 265 of the constitution of lndia and sec 148A of the lncome Tax Act, 1961, and to consequently set aside the same in the interests of justice. Petition under Section 151 cPc prayrng 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 notice issued u/s 148 of the lncome Tax Act, 1961, dated 29.04.2024, bearing DIN and Notice No.. lrBA/AST/s1148-112024- 2st106444419a(1), by the ist Respondent, for the Assessment Year 2017 - 1B; pending disposar of the above writ petition. Counsel for the petitioner: SRI SINGAII SRINIVAS RAO & SRI VIGHNES}I ASAWA, REP. SR! A.V.A.SIVA KARTIKEYA Counsel forthe Respondents: Ms. BOKARO SAPNA REDDY, Sr. SG FOR lT 3 o 1 u Between: S/o. Goverdhan Temple . about 41 years. FUo_ H!,Oerabad - S00 OO3,

#1. harlal

#2. The Assistant No.40t, 9;l'*d.Jl""flE"Iil 8?rum:::9a3,ffi, 1 1 ), Opp.L B Stadium, circumstances stated in Petition under Article 226 of the Constitutio ..RESPONDENTS n of lndia praying that in the the affidavit fiH therewith, the High Court may be 6 pleased to issue a Writ or order or directbn, more preferably in the nature of Writ - of Mandamus, trolding the order passed by the rd respondent herein under sec. 148A(d) of the lncome Tax Act, ciateci. dateci.29.o3.2023 with DIN tlotice No.|TBA/AST,|F t 1 48N2022-23t 1051540024(1 ) for F.Y. 201 8-1 9 relevant to the A.Y. 2019-20 as illegal, arhitrary, bad in Law and violation of Principles of Natuml Justice aPart from being violative of Provisions of Sec.148A and 149 of the Act also otntrary to the circular issued by CBDT and provisions of 'sec.15lA of the Act cons:'equently set aside the same. .Petition under Section 151 cPc praying that in the circumstances stated in the affrdavit filed in support of the petition, the High court may be pleased to Suspend the Operation of the Order dated'29'O3'2D23 with DIN Notice No.ITBA/AST/Ft148Nm22.23t1o5154ao24(1)forF.Y.2018.19relevanttothe A.y. 2o1g-20 passed by the 2nd respondent, pending disposar of the above writ petition. Counsel forthe Fetitioner: Ms' AYYAGART JAYASHREE Gounsel forthe Respondents: lllls' BOKARO SAPNA REDDY' Sr' SC FOR lT o 0 o I lbrahim R/o. ear. zo17-18 about 4V P

#3. I 7 Petition under Article 226 ot lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed thereurith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of wRtr oF MANDAMUS holding that the notice issued (JAo) by 2nd Respondent under section 148 Dated. 28.03.2024 vide DIN No. the Assessment year 2o1t-1a lrBA/AST/s/148-ll2o23-24t1063s09881(tfor and the consequential order passed by the 1st respondent uls. 141 r.w.s 144 read with section 144Bot {he lncome-tax Act Date of order 14.o2.m2s, DlN. lrBA/AST/s/l 47 l2o2+2sl 1ottz9st34('t) for the Assessment year 201 t -1 8, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart from violation of Articles 14, 19 (1 Xg) and 265 of constitution of lndia apart from being violative of provisions of section 1 4gA and section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section 151A of the Act, and consequently set aside the order passed by 1st Respondent u/s. 147 r.w.s 144 read with section 144Bof the lncome-tax Act Date of order 1 4.02.2025, DtN. lrBA/ASTtSt 1 47 12024-251 1 0732957 34( 1 ) for the Assessment Year 2017- 18and all consequential proceedings pursuant thereto. 1 Petition under Section 1S1 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 lst Respondent uls. 147 r.w.s 144 read with section 144B of the lncome- tax Act Date of Order 1 4.02.2025, DlN. |TBA/AS Ttst 1 47 t2024-25t107329s734(1) for the Assessment Yearfrll- 18 and .stay of Demand notice under section 156 Dated. 14.02.2O25 vide DfN No, 5612024-251 1 073295880(1 ) for rhe Assessment yearZOll- ig, pending disposal of the writ petition. Counset forthe petitioner: SRI THANNERU CHAITANYA Counsel for the Respondent No.l & 2: Ms. J.SUNITHA, Sr. SC FOR lT Counset for the Respondent No.3: SRI GENERAL OF INDTA B ltv) Il Limited Madhav no. 1, Telangana-

#1. Assistant Commissioner of lncome Tax Central Qitclg --g(1)iHyderabad ,€yakar Bhavan, Opp. LB Stadium Basheerbagh, Hyderabad' Telangana - 5q)004 2. Central i10001 Eloard of Direct Taxes, Central Secretariat, North Block, New Delhi - Represented by National Faceless Assessment Centre

#3. Commissioner Of lncome Tax (Appeals), lTtowersr, 10-2-3, AC Guards, Hyderabad 11, Sth"Floor, DBlooh 500@4 circumstances under Article 226 of lhe Constitution of lndia praying that in the stated in the affidavit filed therewith' the .Higrh Court may be Writ of Certiorari or any other-appropriate writor direc{ion to set aside the (a) DigitallY S igned Notice u/s' 148 of the Act viOe Ol.l1l Notice No 9t148_1t2o23.24l1059159653(1)dated2}l,l2l2o2sissuedby rder u/s. 147 of the Act bearing DIN and 23-241 1063797895(1 ) daied 31 l0il2o24 hibit P2 and No. 1 in Exhibit P1 (b) DigitallY sitlned Assessment O Order No. ITBA/AST/S/147120 passed by iResPondent No' 1 in Ex (c) DigitatlY signed Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBNAFUSI2SO|Z0 25-26/1082880996( 1) dated 21n1no25 Passed bY ResPondent No' 3 in Exhibit P3' and all other consequential actions' penal and recove being illegerl, arbitrary' unlawful and violative of the lncome-tax Act' 1961 and Articles 14 and 19(1Xg) of ry Prcceedings for provisions of the the Constitution of lndia. l lA NO: I oF m25 9 ,Petition under Section tS't CPC praying that in the circumstances stated in the affidavit filed' in support of the petition, the High Court may b-e pleased to stay the operation of and all recovery and penal proceedlngs in purcuance of the Digitally Signed Notice u/s. 148 of the Act vide DIN and Notice No ITBA/AST/S/148-11&23'2411059159653(1) dated 28.12.2023 issued by Respondent No. 1 in Exhibit Pl Digitalty signed Assessrnent Order uts. 141 af the Act bearing DIN and order No. ITBA/AST/st14712o23-24t1063797895(1) dated 31.03.2024 passed by Respdndent No. 1 in Exhibit P2and pass Digitally signed Appellate Order u/s 2ffi of the Act bearing DIN and Order No. ITBA/APUS l25ol2oz5-lz6t1o8zg8o996(1 ) dated 21 .11 .2o2s passed by Respondent No. 3 in Exhibit P3, and pass any such other order or orders as the Honble Court may deem fit and proper in the circumstances of the case, as the petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Assessement Order and lnnpugned Appeltate O:-der, both of which suffer frcm various tegal and factual infirmities, woutd suffer irreparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this wr:it petition. counsel for the petitioner,: sRr sANTosH SAGAR KAPTLAVA! counser forr the Respondents: sRr N.PRAVEEN REDDY, Sr. SC FOR lT Between: AND

#3. ...PETITIONER mi:Irf; :[rj"#:H'.,gffi #;"?",s5;l,",.Ji?E;o3f i,"d5t1ffi E*l,'"fSil3nffi "?F3[B;:s"{s:H3h},",t"Bp""k,NewDe,hi- ,?flffff ?srrE,,xas,,:"Hffiff:1.3,,?jfl?B?x_JJr3&F'oo,D-Brock, ,)t5lffi H1,"1 IO ...RESPONDENTS- Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issiue Writ of Certiorari or any other appmpriate writ or direction to set aside the 1a1 Oqlitatty Signed Notice u/s.148 of the Act vide DtN AND Notice No |TBA/AST/S/1,18_112023-2411051706172(1) dated 30.03:2023 issued by Respondent N'r.1 in Exhibit P1 (b) Digitally signed Assessment order uls. 147 of the Act bearing DIN and order No lTtsA/AST,'S/147tm23-2411063732453(1) dated 30'03'2024 passed bv Respondent No. 1 in Exhibit P2 and {c) Digitally signed Appellate Order u/s 250 of the Act bearing DtN and order No' dated 21'11'2025 passed bv ITBA/APL/S/25012025-26na82s}5747(1) Rery9nle1t No. 3 in Exhibit P3' and all other consequential actions' penal and recovery prooeedings for being illegal, ar.bitrary, unlawful and violative of the provisions of the lncome-tax Act' i961 and Article:; t+ and 19(1Xg) of the Constitution of lndia' lA NO: 1 OF 202ti 148u12o22'2sttosttoJtTz(1) Petition under Section 151 CPC praying that in'the circumstances stated in the affidavit filr:d in support of the petition' the Higrh Court may'be pleased to stay the operatiorr or ano'Jtt recovery and penal proceedings lRpursuance of the Digitalty Signed flotrce uls*' ra8 of th" Act vide ilN & Nottce No'-ITBA/AST/S/ dated 3o'o3'2o23issued by Respondent No' 1 in Exhibit P1; Digitally tign"d-Ass"'sment Order u/s' 147 of the Act bearing DIN & os17 0617 2(1\ dated 30'03'2023 passed order No. ITBA/A'ST/S/ ;' -' "'o"-"r' by Respondent N'c' 1 in E;;b'rt P2 andpass Digitalty signed Appellate order u/s 25O of the lict o""|.'"n DIN & Order No' [dNAPUS/25O12O25' '"''O'upassed by Respondent No' 3 in Exhibit P3 26t'18828g574"" o"t* and pass any such otne' o'd"' or orders as the Hon'ble Court may deem fit and of tne case' as the Petitioner' being fastened with proper in ttl" "i'""ttJn""t ''' I -.! huge additions to its returned income as a result of the lmpugned Assessrnent Order and lmpugned AppeHate Order, both of which suffer from various legal and factual infinnities, wouU strffer irreparabte hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ petition. Gounsel for the Petitioner: SRr sANTosH SAGAR KAplLAvAt counsel for the Respondents: sRl N.PRAVEEN REDDy, sr. sc FoR lr Between: sai Kumar Thota saikumar, H.No.10-4 -llltE., sri Ram Nagar colony, Masab Tank Flyderabad, Telangana - SOO bZA ENTi] ...PETITIOHER 1' gY{tlon oJ lndia, Ministry of Finance, lncome Tax Department, New Delhi - 100 ' E3?'ffiT*"5rffffiltr8:i;,':?S,'r";l?x Department, Minist ry ot Finance, t ffi":fr*:J?XfrffiL3*:t#Afo u(,), f.$yderabad rr rowers, Ac IiF,#Tgtra?8trff ii,x,.I"il:fi "#iiil?ff,i,,",1,***rtmenr, Ministry ...RESPONDENTS of rndia praying that in the the Fl-rgh court may' be in the qetgte_gf a '1"* particufarlv petition under Article 226 of the Constitu circumstances stated in the affidavit nbo trreltion p!9?:9-9--19- igsue a writ or direction or orde. ,ort*'n' writ of certiorari calins for the ;;;"'::: dated z6twt2o2sbearins o,*'::oo' ;:,::'ashins 3rdRespondent the (,) ,rrrnr"J :",;w',:::,#'#i1: and in viorationu#il,""#ir, iu of the tncome rax Act, 1e61 as beins i,esat re s tra i n th e Respo nd e n ts rro m ff[il1;'"n*::,,# ::: JIT: Notice dated26t06t2o2s. on the basis *,il:fr:ffi;: ,llfil,; "1,'=* t2 petition under Sect'rcn 151 CPC praying that h the circumstances stated in the affidavit filed in suppoit of the petition, the High c6urt may be pleased to stay the operertion of lmpugned Notice dated 26,/0612925 bearing DIN and Notice No. ITBA/AST lsl',l48_1t2o25-26t11r7862610(1fior the Assessrnent Year 2021 - 22,issuedbylheRespondentsunderSection.l,ASofthelncomeTaxAct,196lin the interest of iustice. 3 ?rn Petition under Section 151 CPC praying that in the circumstances stated intheaffidavitliledinsupportofthepetition, theFti$hCourtmaybepleasedto suspend all further proceedings pursuant to the lrnpugned Notice dated 26tOOl2O25 bearing DIN and Notice No'ITBA/AST/SI'148-112025- 26t'1077862610(1) for the Assessment Year 2O21 ' 22' issued by the Respondents unCer Sectionl4Sof the lncome Ta< Act' 196f in the interest of justice.. Counsel for the t'etitioner: SRI SHEETAL SRIKANTH Counsel for the FlesPondent No.l: SRI N GE OF INDIA Counsel for the No.2 to 4: Ms' B'SAPNA REDDY' Sr' SC FOR lT Swathi Guduri' D/o. T T Prestige KokaPet' lncome Tax Unit, Room No.401' 2nd Floor' 110 003.

#1. Assessment New Delhl' New Delht - 2. The Income Tax HYDE Officer' Ward 14(1), lT Torarers' AC Guards' Masab Tank' Center' Nehru Stadium' lncome Tax Telangana'

#3. +:i,.r,$i8'3;?SiiTi"jli "?Iilt.W;J#-;do 13 Petition under Article 226 of the constitution of lndia prayng that in the chcumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ of Mandamus or any other appropriate writ, order or Directhen; declaring the Assessment order passed by the .tst Respondent, u/s 147 rlw Sec. 144 r/w Sec. 1448 ot the lncome Tax Act, 1961, dated 26lo2l2o2s, bearing DlN.lrBA/AST/sl't47t2o24- 2s11o731421o9(1) for the Assessrnent year 2o2o-21, as artritrary, illegal, bad in law, void-ab-initio, violative of the principles of natural justice apart from being violative'of Articles .14, 19(1Xgt) and 265 of the 1961, and of lndia and Sec. 148A of the lncome Tax set aside the same in the interests of justice. 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, incruding any recovery, pursuant to the Assessment order passed by the 1st Respon<lerrt, uls 141 r/w sec. 144 rlw sec. 1448 of the lncome Tax Act, 'r961. dated 26lo2l2o2s, bearing DlN.. lrBA/Asrlsl14ll2o24- 2511073742109('l) for the Assessment year 2o2o-21 pending disposal of the above Writ Petition. Counsel forthe Petitioner: SRt PATURI RAMA KRTSHNA

Counsel fortlre Respondents: Ms. BOKARO SAPNA Sr. SC FOR lT 0 a Il Suresh Tammineedi, S/o. T. Business, F/o. SRT 766, Sanath Nagar, ry, Aged about 55 years, Occ. Nehru Park, HyderaUfo 500018

#1. p.nio.n of lndia, Ministry oJ Finance, Represented by its secretary i66-8, North Block, New Delhi-l 1060l

#2. lncome Tax Officer lrrcome Tax Office AC Guards, Masab Tank, 1), Hyderabad, I T TOWER, 1,4

#3. The National Faceless Assessrnent cenlre, lncome Tax Department, Ministry- of Finance, Govt of lndia, Ne$, Delhi ...RESFONDENTS Petition under Aflicle 226 of the constitution of lndia praying that in the circumstanceri stated in the affidavit filed therewith, the High court may be pleased to t. lssur: a Writ, Order or Dir€c,tion more particulafly, one' in the nature of Writ of Mandamus, declaring the impugned Order under Section 1481(d) of Act bearing DIN Notice No. ITBA/COM|F|17|2O22 - 23110441235'12(1) dated 26.07.2022 and notice u/s. 148 of the said Act daled 26.07.2022 aad consequential'irnpugned assessment order under Section 1'47 read with sectisn 1448 ol the Act bearing DIN and Notice no. ITBA/AST/S/1 47 12023-24/105279797 4('l) dated 12'05'2023 in respect ot AY 2014-15 issued by Respondent no'2 as illegal, arbitrary, bad in law, void ab initio, violative of the principles of natural justioe and being violative of A,rtieles l4;{9 and 265 of the constitution of lndia and consequentlY, To Se;t aside the impugned Order under Section 148A(d) of Act bearing DIN Notice No.lTBAlCOMIFllT12022-2311044123512(1) dated 26.07.2022 and notice u/s. 1rlB of the said Act dated 26-07'2022 and consequential impugned assessment order 'under Section 147 read the Act bearing DtN and Notice no. with section 1448 of 1) dated 12.05.2023 in resPect rrBAr\sT/s/1 47 I 2923-241 1 of Al1 20'14-15 issued by Respondent no-z any consequent proceedings as lacking in jurisdiction. 10F Petition urrder Section 151 CPC praylng that in the circumstances stated in the affidavit fired in support of the petition, the High Court may be pleased to stay of operation of impugned order under section 148A(d) of Act bearing DIN Notice No.lTBNCOMtFllTl2o22-231',1o44123512(1) dated 26.07.2022 and notice u/s. 148 of ther said Act dated 26.07.2022 and consequential impugned assessment ord€r under Section 147 rcad with section 1448 of the Act bearing i l5 DIN And Notice no. ITBA/AST/S/1 472A23-2411052797974(1) dated 12.05.2023 in respect of AY 2014-15 issued by Respondent no.2 irrcluding all further proceedings pending disposal of the main writ petition. COUNSEI fOr the Petitioner: Ms.PRAGAT MAT}IIDEPALLE REPRESENT]NG Ms. SNEHA ASTHANA Counsel for the Respondent No.l: SRI N.BHUJANGA RAO, DEPUW SOLICITOR GENER^AL OF INDIA counsel for the Respondent No.2 & 3: Ms. B.sApNA REDDY, sr. $ FoR lr Between: Nagi f Lim ited,. Having its Office at Survey No.249, Asmangadh, Brahmanapally Village, Hydembbd, Rangareddy Dlstrict Represented by its Authbrized Signatory, Mr.- Seelam 1 2

#3. !.nio.q 9f lndqa,.lrrliryi9lry oJ Finance, Re;rrcsented by its secretary 166-8, North Block, New Delhi-l 1 0001 t-ngoqre Tax officer, lncome Tax office, circle 1(1); Hyderabad, rr rowER, AC Quards, Masab Tank, HYDERABAD, 500004' ' Centre, lncorne Tax Department, Ministry ...PETITIONER Petition under Article 226 of the Constitution of lndia prraying that in the circumstan$es stated in the affidavit filed therewith, the High Court may be pleased to ..RESPONDENTS t- To issue a writ, order or Direction more particularly, one, in the nature of writ of Mandamus, declaring the order passed by the Respondent ttb.z in passing the impugned assessment order dated, 16.04.2024 u/s 14BA(d) bearing DIN Notice No.!rBA/AST/F/148 N2o24- Zpt'lOA+t+2890(1) and a notice bearing DIN and Notice no. IteA/AS7St148_1t2O24-25t1064143160(1) u/s. 148 of the said Act dated 16.04.2024 in respect of Ay.2019-20 as illegal, arbitrary, bad in l{w, void ab initio, violative of the principles of naturaljustice and being l6 violative of Articles 14,19 and 265 ol the Constitution of lndia and - 'con:;equently, ll- To liet aside ttle imp.ugned assessment Order dated 16:O4.2A24 uls. 148/\(d) bearing DIN Notice No.|TBA/AST/F1148N2O24- 2511064142890(1) and a notice bearing DIN and Notice no. lTFr,/AST/S{J48:ll2O24-2511064143160(1)u/s. 148 of the said Act dated 16.04.2024 in respect of Ay. 2o19-2O any consequent proc'?edlngs as lacking in iurisdiction. lA NO: 1 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 of operatii)n of impugned assessment Order dated 16.O4.2024 u/s 148A(d) bearing DIN Notice No. ITBA/AST/F[48-N2024-2511O64142890(1) and a notice bearing DIN ar,d Notice no. ITBA/AST/S/148-1f2o24-25l1064143160(1) u/s, 148 of the said lrct dated 16,.O420X :in respect of Ay. 2019-20 issued by Respondeht no.2 inclutlhg -ll ings pending disposal of the main writ petition. -- -' Counsel for the, Petitioaer: iis.SNEHA ASTHANA Counsel for the Responder* No.I: SRI N.BHUJANGA RAO, DEFUTY SOLICITOR GE}IERAL OF INOIA Counsel for the Respondent llo.2 &3: SRI VIJHAY K.PONNA, Sr- SC FOR tT E I 0 Suresh lrmmineedi, S/o. T. Business, FYo. SRT 766, Sanath agar, D 1. Union of lrrdia, Min Block, Neur Delhi-1 islry of Finance, Represented by its Secretary 166-8, North 10001

#2. lncome Tax Officer, income Tax Office, Ward -12(1), Hyderabad, I T TOWER, AC Guards, Masab Tank, HYDERABAD, 500004 Z{im.f[f{i] t7

#3. The National Faeless Assessment of Finance, Govt of lndia, Nevv Delhi Centre, lncome Tax Depaftrnent, Ministry Petition under Article 226 of the Constitution of lndia praying that in the the High Court may be circumstances stated in the affidavit filed pleased to ...RESPONDEIITS i. ll. lssue a Writ, Order or Direction more particulady, one, in the nature of Writ of Mandamus, declaring the ,irnpugned Order under Section 148A(d) of Act bearing DtN Nothe No. iTBA/COMIF/1il2O22- 2311044123740(1 ) dated 26 .O7 .2022 and notice u/s. .t 48 of the said Act daled 26.O7.2022 and consequential .impugned assessment order under Section 147 read with section i44B of the Act bearing DIN and Notice no. ITBA/AST/S/1 4t t2023-24l1OSZSS4g2O(1) dared 1 8.05.2023 in respect of AY 2015-16 issued by Respondent no.2 as illegal. arbitrary, bad in law, void ab initio, vblative of the principles of natural justice and being violative of Articles 14,19 and 265 of the Constilution of lndia and consequently, To Set aside the impugned Order undei Section 14gA(d) of Act bearing DIN Notice No. ITBA/COM/F/IilZO22-2211O44123740(11 dated 26.07.2022 and notice u/s. 148 of the sairl Act dated 26.01.2022 and consequential impugned assessment order under Section 147 read with section 144[3 of the Act bearing OIN and Notice no. I TBA/AST/S/1 47 I 2023-241 1 052954320(1 ) dated 1 8.05.2023 in respect of AY 2015-16 issued by no.2 any consequent proceedings as lacking in jurisd NO:1OF 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 of operation of impugned order under section 14gA(d) of Act bearing DIN Notice No. lrBA/coM/F/17t2o22-23t1o4412314o(1) dated 26.07.2022 and notice u/s. 148 of the said Act dated 26.01.2022 and conseguential impugned assessment order under Section 141 read with section 1448 of the Act bearing l8 DIN & Nothe no. ITBA/AST/5I14712O23-241105295432O11) dated 18.05.2023 i6 - respec{ of AY 2015-16 issued by Respondent no.2 including all further proceedings pending disposal of the main writ.petition. Counset forthe Petitioner: {US.SNEHA ASTHANA Counsel for the Respondent l.lo.i : SRt N.BHUJAi{GA RAO' . DEPUTY SOLICITORGENERAL OF INT}IA CounseJ for the Respondent No.2 & 3: ils. B.SAPNA REDDY' Sr. SC FOR 1T 0 l Between: CONCORD Asmangadh, Rangarejdy Signatoqr, M DRT GS LIMiTED, Having its Ofiice at Survey No.249 -Haratnaoar Mandal, Brahmanapally Mllage' Hyderabad' Eistrtct S0054, Telangana, Represented by its Authorized r. Seelam Nagi, Reddy ...PETITIONER AND

#1. Union of lndia, Ministry of -' -Bloct<; Nerw€ethi-r+0e01- 2. lncome T'ax Officet lncome Tax Offie, Circle 1(1), Hyderabad, I T TOWER' Finance, Represented by its Secretary 166-8, North AC Guards, MasabTank, HYDERABAD, 500004

#3. The National Faceless Assessment centre, lncome Tax Department, Ministry of Finanoa, Govt of'lndia, lil, ew Delhi ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances rstated in the affidavit filed therewith, the High Court may be pleased to issue:l Writ, freror Direction more particularly, one, in the nature of Writ ol Mandamus, declaring the order passed by the Respondent No.2 in passing the impugned assessment Order dated '16.04.2024 uls 148AGl) bearing DIN Notice No. ITBA/AST/F/148N2O24- 25t1064143412(t) and a notice bearing DIN AND Notice no. u/s. 148 of the said Act ITBA/AST/S/1 48 dated '16.04.2024 in respect of Ay. 2017-18 as illegal. arbitrary, bad in law, void ab initio, violative of the principles of natural justice and being -112024-2511064143654(1) .I t9 ii. violative of Articies 14,19 and 265 of the Constitution of lndia and consequently, To Set aside the impugned assessment Order dated 16.04.2024 uts 1484(d) bearing DIN Notice No. |TBA/AST/F/148N2O24- 2511064143402(1) and a notice bearing DIN AND Notice no. IT8A/A5T/5/148_11202+2511064143654(1) u/s. 148 of the said Act dated 16.04.2024 in respect of Ay. 2O1l-18 any consequent proceedings as lacking in jurisdiction. lA NO: 1 oF 202s Petition under section ,51 cPc praying that in the circumstances stated in the affidavit filed in support of the petition, the High Gourt may be pleased to stay of operation of impugned assessment order dated 16.04.2024 u/s 14gA(d) bearing DIN Notice No. lrBA/AST/Fl1qN2o24-2s11o64143402(i) and a notice bearing DIN & Notice no. lrBA/AST/sl14B_1t2o24-2s11064143654(1) u/s. 148 of the said Act dated 16.04.2024 in respect ot Ay. 2017-18 issued by Respondent no.2 including all further proceedings pendlng disposal of the main writ petition. Counsel for the Petitioner: Ms. SNEIIA ASTHANA Counse! forthe Respondents No.i: SRI N.BHUJANGA RAO, DEruTY SOLICITOR GENERAL OF INDIA Counsel forthe Respondents No.2 & 3: SRI VIJHAY K.PUNNA, Sr. SC FOR lT o 0 0 Between: Suresh Tammineedi, 9o. T.Sdttranarayana, Aqed about 55 vears. Occ. Business, Ryo. SRT 766, Sanath Nagar, Ne Ubnnipa*, XyAeraOSa soOOta ...PETITIONER AND

#1. $io.n of lndia,.Ministry_of Finance, Represented by its Secretary 166-8, North Bbck, New Dethi-110001

#2. lncome Tax Officer,.lncome-lq @ce, Ward -12(1 ), Hyderabad, I T TOWER, ACGuards, MasabTank, HYDERABAD, SOOOO4' ''

#3. The Natbnal Faceless. Ass.essment Centre, lncome Tax Department, Ministry of Finance, Govt of lndia, New Delhi 20 ...RESPONDENTS Petition under Article 2Xi ot lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to a) lssue a Writ, Order or Direction more particularly, one, in the nature of'Writ of Mindamus, declaring the impugned Order under Section 148A(d) of Act bearing DIN Notice No.ITBA/GOM tF I 17 12022'2311 044250699(1 )dated 28.07.2O22 and notice u/s. 14t| of the said Act daled 28.07.2022 and consequential impugned assessment order under Section 147 read with section 144B of the Act bearing DtN and Not'rcrr no. ITBA/AST/S/1 4V 12023-241 1 0527 8807 1 (1) dated 1 2.05.2023 in respect of NY 2O1V-18 issued by Respondent no.2 as illegal. arbitrary' bad in law, void ab initio, violative of the principles of natural iustice and being violative of Articles 14,19 and 265 of the Constitution of lndia and consequently, t. To Set'asidtrttrc impugned Order under Section 14SA(d) of Act bearing 9lN Notice.-No-lTBlVC AIilF.l1.7.12O22-2311O44250699(1) dated 28.O7-2A2:2.and notice u/s. 148 of the sakJ Act dated 28.07.2022 and consequential impugned assessment orcler under Section 147 read with section 1448 of the Act bearing Dl N and Notice' no. ITBA/AST/S/1 47 12023-241 10527 8807 1 (1 ) dated 1 2.05 -2023 in respect ol AY 2017-18 issued by Respondent no.2 any consequent proceedings as lacking in jurisdiction. lA tlo: 1 OF 202E Petition under Section 151 CPC praying that in the circumstances stated in the ffidavit4led in support of the petition, the High Court may be pleased to stayof operation of impugned Order under Section 148A(d) of Act bearing DIN Notice No. ITBA,COM/F/I712022-2311044250699(1) dated 28.O7.2022 and notice u/s. 1,48 of the said Act dated 28.07.2022 and consequential impugned assessment order under Section 147 read with section 1448 of the Act bearing DI N & Notice no. ITBA,/AST lS l 1 47 12023-241 10527 8807 1 ( 1 ) dated 1 2.O5.2023 in respect ot AY 2017-18 issued by Respondent no.2 including all further proceedings pending disposal oi the main writ petition. ! 2t Gounsel for the Petitioner: Iis.,SNEHA ASTHANA Counsel for the Respondent No.l: SRI N,BHUJANGA RAO, DEPUTY SOLICITOR GENERAL OF TNDIA counsel for t]re Respondent No.2 & 3: Ms. B.SAPNA REDDY, sr. sc FoR lr Between: CONCORD DRITGS t-lMtTED, Having its Office at Survey No.249 Asmangadh, _Hay-atn?g?t _ ManOat B6hmanapally Village f[yOeraUZO, Rangared{y_ Qstri-ct 500054, Telangana, Reprbsehted by its Authorized Signatory, Mr. Seelam Nagi Reddy ...PETITIONER AND 1 . HtSf x[J*.ft,1[?iimT Finance, Represented by its Secretary 166-8, North

#2. lncome Tax-OfficerJncome Tax ffice, Circle 1(1), Hyderabad, I T TOWER, AC Guads, Masab Tank, HYDERABAD, 500004' '

#3. The National Facelegs Assess4e!'lt Centre, lncome Tax Department, Ministry of Finance, Govt of lndia, New Delhi Petition under Article 2%i oi the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to ...RESPONDENTS lssue a Writ, fuer or Direction more particutarty, one, in the nature of Writ of Mandamus, declaring the order passed by the Respondent No.2 in passing the impugned assessment Order dated 15.04.2024 u/s 148A(d) , beaiing - DIN Notice No.ITBA/AST/F/148N2O24- 2il1064110900(1) and a notice bearing DIN and Notice no. IT8A/A5T/51148_112024-2511064110957(1) u/s. 148 ot the said Act dated 15.04.2024 in respect of Ay. 2O2O-21 as illegal. arbitrary, bad in law, void ab initio, violative of the principles of natural justice and being violative of Articles 14,19 and 265 of the Constitution of lndia and consequently, To Set aside the impugned assessment Order dated 15.04.2024 u/s 148A(d) bearing DIN Notice No. ITBA/AST/F1148A12O24- !t. 22 2511064110900(1) and a notice bearing 'DlN and Notice no.- |TBI'/AST7S/1 48-112024-2511064110957(1) u/s. 148 of the said Act date,J 15.04.2024 in respect of Ay. 2020.-21 any consequent proceedings as lacking in jurisdiction. Petition under Section 151 CPC praying that in the circurnstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay of operation of impugned assessment Order dated 15.04.2024 u/s 148A(d) bearing DIN Notice No. ITBA/AST|F|148N2O24'25/1064110900(1) ard a notiCe bearing DIN arrd Notice no. TBA/AST/S/148-112024- 2511064110957(1) u/s. 148 of the said l\ct dated 15.04.2024 in respect of Ay. 2020-21 issued by Respondent no.2 .including all further proceedings pending disposal of the main writ petition. Coursel for Ore Petitioner: Ms. SNEHA ASTHANA Eouisei forther Respondent No.f : SRI N.BHUJANGA mO, DEPUW SOLICITOR GENERALOF TNPIA C.ounselforthe Respondent No.2 & 3: SRI VIJHAY KjPUNNA Sr. SC FOR lT :l o Mr. Balanami Occ. re, Muli, S/o Mr. Chinna Rami 538/3RT, Flat No. 404, Saraca 50O 038, Telangana. Muli, Et t. The lncorne Tax Officer, Ward 14(1), Hyderabad, lT Towers, AC Guards, Maseib Tank, Hyderabad - 500 O04, Telangana.

#2. The Principal Chief Commissioner of lncome Tax, AP and TS, Room No.. 922,'gth Floor, B-Block, LT.Towers, 10-2-3, AC Guards, Hyderabad - 500 O04, Telarrgana.

#3. Assessment Unit, lncome Tax New Delhi, Room No.. 4O1,2nd New Delhi - 110 003. National e-Assessment Center, , E-Ramp, Jawaharlal Nehru Sladium,

#4. The Joint Commissioner ( (Appeals), National Faceless Commissioner of lncome Tax Centre, Delhi, Through the Principal 23 Chief Commissioner 110 001 . of lncorne Tax (NaFAC), Delhi, North Block, Nor Delhi - Petition under Article 226 ot lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ of Mandamus or any other appropriate writ, order or Direction, declaration that the order passed by the 3rd Respondent, uls 141 rtw Sec. 1448 of the lncorne Tax Act, 1961, dated O4.O1.2O24, bearing DlN. lrBA/Asr/s/14712o23- 24l10s9366089('l), for the Assessment year 2o1s - 16 as confirmed by the order of the 4th Respondent dated 10.10.202s, vide DIN and Order No. 081639957(1), passed u/s 250 of the lncome Tax Act, 1961, as arbitrary, illegal; barred by limitation, bad in law, void- ab-initio, violative of the principles of natural justice, apart from being violative of Articles 14, 19(1Xg) and 265 of the constitution of lndia and Sec 1484 of the lncome Tax Act, 1961, and consequenfly set aside the same in the interests of justice. Petition under section 1sl 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 3rd Respondent, uls 141 r/w Sec. ,1448 of the lncome Tax Act, 1961' dated o4.o1.n24, bearing DtN.. trBA/ASTlst147t2o23-24/10s93660a9(1), for the Assessment Year 201s - 16 as confirmed by the order of the 4th Respondent dated 10.10.2025, vide DIN and Order No.. 2611081639957(1), passed u/s 250 of the lncome Tax Act, .1961, pending disposal of the above Writ Petition. Counsel forthe Petitioner: SRt SINGAM SRINIVAS RAO & SRI VIGHNESH ASAWA, REP. SRI A.V.A.SIVA KARTIKEYA Counsel for the Respondents Sr. SG FOR lT t $ T o T 24 Sistu Krishna Rao, S/o. Sistu Commission Merchant Center, :Sarapaka thad about 57 .No.11.55/1 Business, rachalam-507128 Telangana ,2nd , Occ. Line, Lorry freigttt Oinima Hall

#1. The National Faceless Assessment Center, lncomedax Department, New Dethi, lnlia.

#2. lncome Tax Officrr, Ward-1, Koftragudem 6-12'38, Ganesh ternple Main Road Kothagudem, Telangana 3: The Assessment Unit lncome Tax Department Ministry of Finance, Governnrent of lndia

#4. Union of lndia, Ministry of Finance Room No' 134' No(h Block'New Delhi Petition under Article 226 ot lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the +ligh court may be pteased to issu,: a wrlt, order or direction more particularlpin the nature ofja wrjt of Mandamus declaring the order under Section 148A(d) ddled 29,03-2024 hearing DIN and Notice No. ITBA/AST/F/148N2O23-241 1063590548(1) and the consequent notice dated n.03.2o24 u/s 148 bearing DIN and Notic-e No. ITBA/AST/S/1 4tl_1t2'23-24t1063715133(1) and the consequential assessrnent bearing DlN. ITBA/AST1SI147I2O24-2511O737O9393(1) dt.25l02l2025 for the . assessment ye, ar 2017- as being void, illegal, arbitrary, without jurisdiction. violative of Article 14 of the Constitution of lndia and consequently set aside the FFtiir, OF 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 consequent to assessment order uls '147 of the Act bearing DIN: lTEttu AST/S/147l 2024-2511073709393(1) dt'-25l02l 2025, pending disposal of the writ Petition. Counsel for the l'etitioner: SRI KAILASH NATH.P.S.S 25 counsel for the Respondent No.l to 3: SRI N.PRAVEEN REDDy, Sr. Sc FoR lT Gounsel for the Respondent No.4: SRI N.BHUJANGA RAO, DEPI'TY SOLICITOR GENERAL OF ]NDIA - Between: Age. 45 K. ...PETITIONER NND

#1. Assessment Unit,. Roorn No.401, 2m 003. bcomq Tax Department, National e-Assessment Center, Floor, E-Ramp, Jawaharlal Nehru Stadium; Nerr Delhi-116

#2. lncome Tax..officer, Ward, -8(1), Pclr./ Signature Torrers, Kondapur, Serilingampally, Hyddrabad, iehhgiina-SO00b4.

#3. Comrnissioner of tncome tax (Appeals), Nationat Faceless Appeal Centre (NFAC), C-Block, 4th Floor, S P'M Civic Centre, New Delhi - 1rcbil

#4. Prineipal Chief Commissioner of lncome Tax,, Andhra Priadesh and Telangana, -[y{erabad 10-2-3, Room No.g22, 9th Floor, 13'Brock, trrowers, AC Guards, Hyderabad-SOO 004.

#5. Union of lndia, rep. by its Secretary, Ministry of Finance, Govemment of India, 3rd Floor, Jeevan Deep Building, Sansad Marg, New Dethi-l10 001 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ of Mandamus or any other appropriate writ, order or direction ...RESPONDENTS a) declaring the notice under Section 148A(b) dated3l .O1.2024, Order under Section 148A(d) datedl4.O3.2O24 and Notice under Sectircn 148 of the lncorne Tax Act, 1961, dated27.o3.2o23, passed by 2nd Respondent for the assessment year 2O2O-21 as being without jurisdiction and contrary to faceless assessment procedure laid down in Section 144Bof the lncome TaxAct 1961 and consequently. b) to set''aside the subsequent proceedings in order under Section 147 dated 03.03.2025 issued by the 1st Respondent and proceedings under Section 250 dated 15.12.Z025issued by the 3rd Respondent for ttre assessment ?6 yeat 2gm-27 as being without Juriscliction, arbitrary, illegal, bad in law, void-ab-initio, apart from being violative of Art'r:les 14, 19(1Xg) and 265 of the Corrstitution of lndia and contrary to faoeless assessrnent procedure laid dorrrrn in Section '1448 ot the lncome Tax Act 1961 and consequently sehaside the same in the interests of iustice. 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 grant stay of rrll further proceedings, including any rccovery, pursuant to the impugned notice under Section 148A(b) dated3l.O1.2O24, oder under Section 148A(d) dated14.03.2o24 and notice under Section 148 dated 27.O3.2024 issued by the 2ndRespondent, under Section 147 trelad with Sections 144 and144B ot the lncome Tax Act, 1961for the assessment year 2O2O-21 subsequent proceedings in order under Section 147 dated 03.03.2025 issued by the 1st Respondent arrd proceedings under Section 250 dated 15.12.2025, pending disposal of the Writ Petition as otherwiss fh-e Petitioner will be p0t io severe loss and hardship. Counsel forthe Petitioner: Ms. AKRUTI AC,ARWAL Counsel for the Respondent No.l to 4: Ms. J.SUNIIil{4 Sr. SC FOR lT Gounsel for the Respondent No.5: SRI N.BHUJANGARAp DEPUW1SOLIC]IOR GEI{ERIAL OF INDIA Between: DCS Limiled, 169, Road No s00096 1 by its Authodsed Prashasan Nagar, Jubilee V. Sridhar Plot No. bad, Telangana - . ...PETITIONER D 1. Office of lhe Assistant Commissioner of lncome Tax, Central Circle-2(3), lncome Ta.x Department, Hyderabad

#2. Director General of lncome Tax (lnv), lncome Tax Department, Hyderabad. 3. Union of lndia, represented by its Secretary to the Government, Ministry of Finance, N,ew Delhi-'t 10001 27 Petition under Article 226 of lhe Constitution of tndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ, Order or Direction, more particularly one in the nature of Writ of Mandamus or any other appropriate writ dectaring and setting aside (i) the Notice dated 14.08.2024 vide DIN and Notice No F/148A(SCN[2O24-251167661842 (11 issued under Section 148A(b) of the lncome Tax Act, 1961 (ii) the order dated 30.08.2024 vide DIN and Notice No. ITBA/AST/F/1 48N2O24-251 10681 91 804( 1 ) passed under Section 1 48A(d)' of the lncome Tax Act, 1961 (iii) the Notice dated 30.08.2O24 vide DIN and Notice No. ITBA/AST/S/1 48_1 12024-251 10681 931 55(1 ) issued under Sec.tion 148 of the lncome Tax Act, 1961 (iv) Notice issued under section ,l44Zl read with section 147 of the income tax Act, 1961 vide DIN.ITBA/AST/FI141(2\2O24- 2511071217136(1) dated 13.12.2024 (v) Notice under sub-section 142(1) of the lncome Tax Act, 1961 vide DIN and Notice No. ITBA/AST/F/142(1112O25- 2611081988431(1) dated 24.10.2025 as iltegal and for being without jurisdiction as it is issued by jurisdictional assessing officer, as it is passed without the authority of law, or to issue any other appropriate Writ or order as this Honble High Court may deem fit and proper in the circumstances of the case. 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 pursuant to the Notice dated 30.08,.2024 vide DIN - and-Notice No'ITBA/AST/51148_112024-25|'1O6821131S(1) issued.under Section 148 of the lncome Tax Act, 1961 , pending disposal of the writ petition. Counse! forthe Petitioner: SRI SANDEEP SRIPADA, REP. Counsel for the Respondent No.l & 2: Ms. J.SUNITHA, Sr. SC FOR lT Counsel forthe Respondent No.3: SRI N.BHUJANGA RAO DEPUTY SOLICTTOR GENER1AL OF INDIA I o 0 I 28 Arcade, Telangana, {ndia Aged about 25 No. 127, VasaM Presently residing at 1002 San Jachto, Dr., tlnit 332, lrving , Dallas, Texas, 75063 '-ERPPM0079B ReEesntd"byherFatherSpecial, Power of Attomey, Raghu Kumar Manchukonda Ill=fifitrNl=trl

#1. Assistant Commissioner df lncorne Tax, Central Bhawan, Opp. tB Stadium, Basheer Bagh, 4 Hyderabad Telangana-

#2. TIE Principal Commissioner of lncorne Tax Bhawan, Opp. LB lncome Tax Hyderabad,

#3. The National Faceless Assessment Centre, lncome Tax Department, Ministry of Finance, Ministryef Firancer (o.rt- * I'dta, roQ t, DQI"LJ .

#4. The Prin,:ipal Commissioner of lncome Tax (Appeals)-ll, Hyderabad lnmme Tax Towers, AC Guards, Govt of lndinaNew Delhi.

#5. Union of lndia, Ministry of Finance, Rep. by fis Secretary, 166-8 North Block, New Deltri - 110 001. Petition under Article 226 of the Qonstitution of'lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to (i) (ii) lssue a Writ, Order or Direction more particularly, one, in the nature of Writ cf Mandamus, declaring the action of the Respondent No.'l in issuin.q Notice u/s. 148 dated OSlO2l2g24 'calling for return of income for A.f. 2021-22, assessment order dated 1110312025, the Penalty Order u/s 2718 dated 22l0gl2025 and subsequent proceedings as illegal, arbitrary, bad in law and violative of Artickes 14, 19 and 265 of the Constitution of lndia, and declarring the action of the Respondent No.1 in issuing Notice u/s. 148 daled OSlO2l2024 on the premise that the search u/s '132 was conducted in case of Petitioner, whereas no search under section 132 & 29 was actually conducted in case of the Petitioner, thereby the jurisdiction assumed by Respondent No.1 is illegal, arbitrary, bad in law and violative of Articles 14, 19 and 265 of the Oonsiitutlon of lndia, and (iii) Set aside Notice issued u/s. 148 daleld OS1OZI2O24 calling for retum of income tor A.Y.2O21-22, assessrnent order daled 111o312025, penalty order dated 22.09.2025, and any consequent proceedings as lacking in jurisdiction. l Petition under Section 151 CPC praying that in the circumstances stated in the afftdavit ftled in support of the petitinn, the High Court may be pleased to grant an interirn stay on the operation of Notice issued u/s. 148 of lncome Tax Act, 1961 by Respondent No.1 dated OSlO2l2V24 calling for the retum of income of the Petitioner lor A.Y.2O21-22, assessment order daled 111O312025, penalty order dated 22l0gl2il25 and further stay all consequential proeeedings initiated or contemplated by the Respondents, pendins disposal of the writ petition. Counsel forthe Petitioner: SRI P.SOMA SHEKAR REDOY Counsel forthe Respondent No.l to 4: SRI N.PRAVEEN REDDY,3r. SC FOR !T Counsel forthe Respondent No.5: SRI N.BHUJANGA RAO, GENERTAL OF INDIA o u )h' Narayana Ravisetty, Employee, Rl/o H.l,lo Mancherial, Telangana-S043o2. S/o Pochaiah, 7-160116t1, D 1 . The lncome Tax OfiFcer Ward-1 , Adilabad, Telangana-504106. 2. The Chief Commissioner of lncome Tax, Hyderabad, l.T. Torrers,A.C. Guards, Hyderabad, Tel

#3. The Assessment Unit, lncome Assessment Centre, Delhi, Mi Ramp, Jawaharlal Nehru Stadium,

110003. National Faceless 4Ot,2nd Floor, E- .RESPONDENTS 30 Petltion under Article '226 ot the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court rnay be pleased to issrre an appropriate writ order or direction more particularly one in the nature of Writ of Mandamus, declaring the .Assessment Order dl. '17.O1.2025 passed by the 3d respondent vls 147 r.w.s 14411448 of the lncome-tax Act for A.Y.2o17-1tt vide DtN No. ITBA/AST/S/14V12O24-2511072272959(1), consequent to the order passed u/s 148A(d) dt.27.02.2024 vide DIN No. ITBA/AST/F/I 48N?o,23-241'1O61607 47 O(11 and the notice u/s 1 48 dt.27 .O2.2O24 vide DIN No. ITBtuAST/S 11 48-1 12023-24/1 061 607803(1 )issued by the JAO(lst respondent) instead of FAO(3rd respondent)that too based on the incorrect information and without properly considering the submissions placed on record, and consequential penalty order.passed vide order u/s 272A(1)(d) of the Act dt. 1O.O7.2025 as 'void, illegal, and contrary to the provisions of lncome-tax Act and contrary to the Principles of Natural Jtirstice. Petition under Section 151 CPC piayin-g tha't in the circumstances stated in the affidavit filed in support oI the petition, the High Court may be pleased to stay all further proceedings pursuant to the Assessment Order dt. 17.O1.2lzspassed by the 3rdrespondent u/s 147 r.w.s 14411448 of the lncome- tax Act for A.Y. 2017-78 vide DIN No. ITBA/AST/5114712024-2511072272959(1) and the Penalty orders, pending disposalof the writ petition. Counsel for the Petitioner: SRI DUiIDU SASHANK, REP. Counse! forthe RespondenG: *ts. J.SIINITHA Sr. SC FOR lT 3 5 0 t] Mubeen Khan, S/o. Late Sri Mohd Abdul Khan, 15-$431, Aged 50 years, Opp. Munrralal Dawasaz, OH Santosh Nagar, Babepur, Hyderabad - 500 012 PAN No: ALRPK9419M u=ftftoNEnl D 1 . The lncomr: Tax Officer, Ward - 7(1), Hyderabad. 3l

#2. The Assessrnent Unit, Govemment of lndira, lncome Tax Department, Ministry of Finance, Delhi.

#3. The Union of lndia, Rep. by its Secretary, Ministry of Finance, 64, 3rd Floor, - Jeevan Deep BuildirB, Sansad Marg, l.leiv Delhi.

#4. Ihe Branch Manager, Axis Bank Ltd, 'lst Floor, Gulzar House, Charminar, Hyderabad - 500 021 State ofTelangana ...RESFONDENTS Petition under Article 226 of the Constitution of tndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Mandamus or any other appropriate Writ or Order or Direction declaring- (1)the action of the 1st Respondent in issuing Notice under Section 148 of the lncome Tax Act, 1961, dated 30.03.2023 for the Assessment Year 2016-17, instead of issuing by the National Faceless Assessment Centre, as null and void, illegal and contrary to the Provisions of the lncome Tax Act, 1961 , without jurisdiction and in violation of Principles of Natural Justice and Rule of Law, against Article 14, 19(1 )(g) of the Constitution of lndia is not valid in the eye of law and (2) the action of the 2' Respondent in passing the Assessment Order, dated 01.O1 .2024 under Section 147 read with Secticin 144 and 144 B of lncome Tax Act, 1961, for the Assessment Year 2016-17, without granting sufficient opportunity and without considering the explanation of the Petitioner passing the Assessment Order as arbitrary, contrary to the provisions of the lncome Tax Act 1961 (3)the action of the 2nd Respondent in passing the Assessment Order, dated 01 .A1.2O24, as null and void, illegat and: contrary to the Provisions of the lncome Tax Act, '1961 , without jurisdiction and in violation of Principles of Natural Justice and Rule of Law, and consequently set aside the Assessment Order, dated O1.O1.2O24 passed by the 2nd Respondenl under Section 147 read with 144 and'144 B of the lncome Tax Act, 1961 for the Assessment Year 2Ot6-17. lA NO: 1 OF2025 32 Petition under Section 151 CPC praying that in the circumsta-nces stated in the affidavit filed in support of the petition, the High Court may be pleased to- suspend the operation of Gamishee Notice dated 23.09.2025 issued by the 1st Respondent to the 4th Respondent. Bank forthwith, pending disposal of the above Writ Petition otherwise the Petitioner will be put to severe loss and hardship. lA NO: 2 OF 2025 Petition under Section 151 CPC praying that in the circumstances stated in the affrdavit filed in support of the petition, the High Court may be pleased to grant stay of all fuilher Proceedings in pursuance of the Assessment Order, dated 01 ,01,20'24 passed by the 2nd Respondent for the Assessment Year 2016- 17, and consequential Penatty Notice dated 01 .01 .2024 issued by the 2nd Respondent under Sec*ion 274 read wfth Section 271 (1) (b) of the lncorne Tax Act, 1961, pending disposal of the above Writ Petition, as otherwise, the Petitioner will b,e put to severe loss and hardship. Counsel forthe Petitionen SRI MOHAMMED RAFI, REP. Ms. SHAIK VAHEEDA SUSHMA Counsel forthe RespondentNo.l & 2: ltlls. BOKARO SAPNA REDDY, Sr. SC FOR lT Counsel forthe Respondent.No.3: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERIAL OF INDIA Beh, Yeen: Surendra Nath Chowdary Pathuri, Age. 42years, Occ. Business, S/o. Pathuri, H.No 2-904 Aunrnonilanka, Aunmonilanka Nallajarla Mandal, West Godavari 53417 6, /\ndhra Pradesh. AND

#1. lncome Tax fficer, Ward (Circle) 11(1), Hyderabad 2. The Principal Chief Commissioner of lncome Tax, AP and TS, 10th Floor, C- Block, l.T.Towers, 10-2-3, A.C. Guards, Hyderabad -500004 ...PETITIONER 33

#3. Assessrnent Unit, National Faoeless Assessment Centre lncome Tax Finance Room No. zl01 2nd Floor, E-FIamp Delhi- 1'10003 istry of Stadium, Lml rlal Nehru n Petition under Article 226 ol lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more particularly one in the nature of Writ of Mandamus, declaring the Assessment Order daled 1710312025 passed by the 3rd respondent uls 147 r/vrr section 1448 of the lncome Tax Act for A.y. 2017-18 vide DIN No. IT8A/A5T/511471202+2511074561136(1) and the notice u/s '148 dated 3O.O3.2O23 vide DtN No. ITBA/AST/S/149 11m23- 2411063680576(1), issued by the JAO (1st Respondent) instead of FAO (3rd Respondent) as void, illegal and contrary to the Principles of Natural Justice. 1 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 pteased to stay all further proceedings pursuant to the Assessment Order dated 17.O3.2O25 passed by the 3rd respondent uls 147 r/wsection 1448 of the lncome Tax Act for AY 2016-17 vide DIN No. IT8A/A5T/5/14712024-2511074561136(1), and may pass such other orde(s) as the Hon'ble Court deems fit and proper in the interest of substantial justice, as othenrvise the petitioner urould be put to irreparable loss and serve injury. Counsel for the Petitioner: SR! PARIKSHITII KUTUR Counsel for thc Respondents: It[s. J.SUNITHA Sr. SC FOR tT o 0 u Mardhani Slokat .Bhai, S/o Habeeb Bhai, Aged abod. 72 years, Occ- 'Nagar .B.ushess, . ?1-!6!11220, Happy Homes Hyderabad-500048 'Up-parpalty, Rajeridra

#1. !1c9me Tax Officer, Circle - 8(1), Hyderabad Signature Towers, Kondapur Hyderabad- 500084 _=;t 14

#2. The Chief Commissioner of lncome Tax, AP AND TS, l0th Floor, G Block, l.'f. owers, 1 0-2-3, A.C.Guards, Hyderabad -500004

#3. Cenke lncome Tax - 2nd Floot E-Rarnp Pelition under Articlg 226 of the Constitution o1 lndla pfayjng that in the circumstances stated in the affidavit filed therewith, the High Cogrt may be pleased to issue a writ, order or direction, more particularly one in the natrlre of Writ of Mandarnus, declaring the Assessment Order dated 26.03.2025 passed by the 3rd resporrdent uls 147 r/w section 1448 of the lncome Tax Act for A.Y. 2017-18 vide DIN No. ITBA/AST/S,114712024-2511O75O42802(1) and the notice u/s 148 dated 13.03.2024 vide DIN No. iTBA/AST/F/148N2C|B- 24t1ffl25523}1{1); issued by the JAO (1st Respondent) instead of FAO (Srd Respondent) ar; void, illegal and contrary to the Principles of Natural Justice. !A t{O: 1 AF 2025 Petition rrnder Section 151 CPC praying that in the circumstances stated in the affrdavit tfiled in support of the petition, the High Court may be pleased tb stay all further lrroceedings pursuant to the Assessment Order dated 26.03.2025 passed by the 3rd respurdent uls 147 r/w section 1448 of the lncome Tax Actfor A.Y 2017-'18 viide DIN No. ITBA/AST/5114712O24-2511O75O428O2(1) and may pass such other orde(s) as the Honorable Court deems fit and proper in the interests of substantiat justice, as otherwise the Petitioner would be put to irreparable loss and serve iniury. Counsel for the Petitioner: SRI PARIKSHITH KUTUR Counsel for the Respondents: Ms. J.SUNITHA, Sr. SC FOR lT t] o n Srinivasuhr Vallamkonda, S/o. Shankaraiah Vallamkonda, Aged about 63 Business, 2-249, old Beet Bazar, Ja ngaon, Warangal,

#167. 35 NNTI]

#1. The lncome Tax fficer Ward-l 610, 3rd l, lncome Tax Office, D. No. 1& Bhawan, Nakkatagutta,

#2. Cornmissioner of lncome Tax-1 Tank, ffier:abad, , lT Towers, AC

#3. The Assessmerf Ramp, Jawahadal Unit, Delhi, lncome Tax Stadium,

110003. National Faceless Room No. 4O1,2nd Floor, E- IlI*{f.T$TillE Petition under Article 226 of lhe Constitution of lndia prayrng that in the circumstances stated in the affidavit filed thgrewith, the High Court may be pleased to issue an appropriate writ order or direction more particularly one in the nature of Writ of declaring the Notice u/s 148 dt. 29.O7.2o22issued by the lst Respondent for A.y. 2O1Z-18 vide DIN No. |rBA/AST/M/1 48-112o22-2a1044g3821g(1), consequent to the order passed u/s 1 48A(d) dt. 29.07.2022 vide DIN No. |TBA/COM tF I 17 tA12z-z3t 1044310327 (1t and issued by the JAO(lst rgspondent) instead of FAO(3rd respondent) and consequential orders, set-asirJe assessment proceedings and penalty order passed videorder uls 272A(1){dhf the Act dt. 28.11.2023,as void, iltegal, and contrary to the provisions of lncome-tax Act and contrary to the principles of Natural Justice. 1 Petition under Section 151 CPC praytng that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay all further proce-edings pursuant to the Notice u/s 148 dt. 29.07.2022issued by the 1st Respondent for A.Y. 2017-18 vide DIN No. tTBtrUASTTMll4B_1t2O2z- 2311044338218(1) and the Penalty orders, and may pass such other orde(s) as the Hon'ble Court deems fit and proper in the interests of substantial justice, as othenarise the petitioner would be put to irreparable loss and severe injury. Counsel forthe Petitioner: SRI DT NDU SASHANK, REp. :t Counsel for the Respondents: Ms. BOKARO SAPNA REDDY, Sr. SG FOR lT 36 ,l Between: Tricotour Properties Private Limlted,_ 4 ?lvqle_LiryitedrCornpany ingorpqratgd under Grmpin'res Act, 1956 D.No.6-3-25114, Balapura, Road no, 1, E?lia1q ttiHi, brihind GVK inall, Khairatabad, Hyder:abad, Telangana- 500034 Repiesented by its Authorized Signatory Mr. B. Madhav ...PETITIONER AND

#1. Assistant Commissioner of lncome Jax, Cqntel Itlclg -.3(1),_HJderabad Aayakar Bhavan, Opp. LB Stadium Basheerbagh, Hyderabad, Telangana - 500004 Z. @ntral Eloard of Direct Taxes, Central Secretariat, Nqrt! Block, Nevv Delhi -

11.Q001 Flepresented by Nat'ronal Faceless Assessment Centre

#3. Commissioner Of lncome Tax lT Towen;, 1O-2-3, AC Guards, (Appeals), Hyderabad- 11, 5th Floor, E)-Block, Hyderabad, Telangana 500004 .RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumsiances stated in the affidavit filed therewith, the High Court rnay te pleased to-issur: Writ of Certiorari or any other appropr, iate-writ-or direction'to'set aside the. {a) Digitally Signed Notice u/s. 148 of the Act vide DIN and Notice No. |TBA/AST/S1148_112023-2411059159653(1) dated 28.12.2023 issued by Reqpondent [rlo. 1 in Exhibit P1. (b) Digitally signed Assessment Order u/s. 1 47 of the Act bearing DIN and Order No. ITBA/AST/St',47t2O23-2411063797861(1 ) dated 31.O3.?fl24 passed by Respondent No. 1 in Exhibit P2. and (c) Digitally signed Appellate Order u/s 250 of the Act beariing DIN 86 Ofder t{o. ITBA/APL lg250,t2}25-2611082577354(11 dated 21.11.2025 passed by Respondent No. 3 in Exhibit P3. and all other consequential actions, penal and recovery proceedings'for being illegat, arbitrary, unlaMul and violative of the provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. 37 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 the operation of and all recovery and penal proceedings in pursuance of the Digitally Signed Nolice u/s. 148 ot the Act vide DIN and Notice No. ITBA/AST/S/148_112023-2411059159658(1) dated 28.12.2023 issued by Respondent No. 1 in Exhibit Pl; Digitally signed Assessment Order uls. 147 of the Act bearing DIN and, Order No. IT8A/A5T/3/14712023-2411063797861(1) nt No. 1 in Exhibit P2 and pass Digitally dated 31.03.2024 passed by signed Appellate Order u/s 250 of the Act bearing DIN and Order No. lTBNAPUSl2fil2O25:251t1O82877354(1) dated 21.11-2025 passed by Respondent No. 3 in Exhibit P3 and pass any such other order or orders as the lion'ble Court may deem fil and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Asiessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer ineparable hardship if coercive re@very is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel forthe Petitioner: SRI SANTOSH SAGAR KAPILAVAI Gounsel forthe Respondents: SRI N.PRAVEEN REDDY, Sr. SC FOR lT o I Devi about 61 8, Road years, No.1O ..PETITIONER D 't. Assessrnent Unit, National Faceless Assessment Centre, lncome Tax of Finance, Room No. 401, 2nd Floor, E-Ramp, Jawaharlal Delhi - 110 OO3.

#2. The lncome Tax Officer, Ward 14(1), Hyderabad/ I T Tower, Ac Guards, Masab Tank, Hyderabad, Telangana, 500004

#3. Union of lrdia, Represent by Secretary Ministry of Finance North Block, New Delhi-l 10 OOI € 38 n Petition under Article 226 of the Constitution of lndia praying that in the circurnstances stated in the affidavit filed therewith, the High Gourt 'may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of rlrRlT OF MANDAMUS holding that the notice issued by the 2nd Rgspo-n{e4t q/s. 148 oI the {-ct, _d_t,?9 .O8.2O24 with DIN No- ITBA/AST/S/1 tl8_112024-25/1068133344(1) for the Ay. 201&tt9, as arbitrary, illegat, bad in law, void ab initio, violation of principles of natural justice apart from violative of Articles 14, 19 (1 Xg) and 265 of constitution of lndia, apart from being violative of provisions of section 148A and section 149 of the [ncome Tax Act and also contrary to the circular issued 'by GBDT and provisions df section 15:tA of the Act, and consequently set aside the order paqsed by 2nd with DIN No- Respondent u/s. 148 of the Act, dt.29.08 ITBA/AST/S/148_112024-2511068133344(1 ) for the Ay. 2018-19 and all consequential .proceed ings pursuant thereto. lA NO: 1 OF 2OXt Petition rrnder Section 151 CPC praying that in the circumstances stated in the affidavit liled in support of the petition, the Higth Court may be pleased to stay all further grroceedings, including any recovery, pursuant to the order passed by the 2nd Respondent u/s. 148 of the Act, dt.29.08.2424 with DIN No- ITBA/AST/S/148_'l12024-2511068133344(1) for the Ay. 2018-19, pending disposal of the rurit petition. Gounsel for the Petitioner: SRI THANNERU CHAITAi{YAKUilIAR Gounsel for the Respondent No.l & 2: Ills. Sr-SC FORrT Counsel forthe Respondent No.3: SRI MORE SllASHl KIRAN, SC FOR CENTRAL GOVT. 3 I I] o I Burugula ltaji Reddy, S/o. Burugula Muthyam Reddy, Occ. Business Rl/o. H.No.1-63 Ravelli, Toopran, Telangana, lndia- PAN.BYBPR4I 56C, Assessment Year. ,about 6-17 39 ...PETITIONER AND

#1. Assessment Unit, National Faceless Assessrnent Centrer lncome Tax DepafUnent- Ministry of Finance, Room No. 401, 2nd Ftoor, E-Ramp, Jaraharlal Nehru Sbdium, Delhi -'110 003

#2. The lncome tax officer, Ward 1, SiddipeU lncome Tax ffice, 8-1-22, 1sl Floor, Subhash Road, Siddipet, Tillangana-s02'l 03

#3. Union oJ lndia, Ministry of Finance North Block, New Delhi-11fi)0'l ..RESPONDENE; Petition under Article 226 of the Constitution of lndia prai, ing that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of WRIT OF MANDAMUS hotding that the notice issued by 2ndRespondent under section sectionl4T r.w.s 144 read with section 144Bof the lncome-tax Act Date of Order 06.01.2025, DlN. ]TBA/AST/S/14712O24,- 2511071897647(1) tor the Assessment Year 2016-17, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart frsm violation of Articles 1a; 19 (1Xg) and 265 of constitution of lndia apart from being violative of provisions of section 148Aand section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section 1 51A of the Act, and consequently set aside the order passed by 1st Respondent u/s. section 147 r.w.s 144 read with section 1448ot the lncome-tax Act Date of Order 06.01.2025, DtN. ITBA/AST I S I 1 47 12024-251 1 OT 1 897 6 47 (1 | tor the Assessment Year 2O1 6-17 and all consequential proceedings pursuant thereto. lA NO: I OF m25 ' 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 1st Respondent u/s. section 147 r.w.s 144 read with section 144Bof the lncome-tax Act Date of Order 06.01.2025, DlN. ITBA/AST/S/'1471&24- 2511071897647(1[or the Assessment Year 2016-17and stay of Demand notice under section 156 Dated. 06.01.2025 vide DIN No. IT8A/A5T|S115612024- 2511071897777(11 tor the Assessment Year 2016-17, pending disposal of the writ petition. 40 Gounsel for the Petitioner: SRI THANNERU CIIAITANYA KUMAR Gounsel for thre Respondent No.l & 2: SRI K.ST DHAKAR REDDY, Sr, SC FOR lT Cor.rnsel for thre Respondent No.3: SRI N.BI{UJANGA RAO, DEPUTY.SOLICITOR GENERAL OF INDIA Between: Mr. Nasar Bin Salem Babader, S/o. Mr.Salam Bin Sayeed, aged 62 yearc, Occ. Private Empficyee, D. No.18-11-2814, Mumtaz Bagh Silata, ebrkas, Chand rayangufta, l-iyderabad 500 005, Telangana. Presently residing at Villa No. 3, Al Nandah Al Askariah, ln front of Roudat Abdulla lMosque, Baniyas, Abu Dhabi, UAE. AND

#1. The lnc, rme Tax Officer, Ward 9(1), Hyderabad, 70-2-3, l.T.Towers, AC Guards, Masab Tank, Hyderabad - 500 004, Tdlangana.

#2. The Principal Commissioner of lnconre, l-[denibad-4, Aayakar Bhavan, LB Stad i um Road, Basheerbagh, Hydera bad-500004 Telangana. ..PETITIONER ...RESP{ONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewlth, the High Court may be pleased to issrre a Writ of Mandamus or any other appropriate Writ, Order or Direction, declaring that, the order passed by the 1st Respondent, uls 147 r/w/s 144 of the lncome Tax Act, 1961, dated 21.O3.2A25,bearing DIN and Notice No. ITBA/AST|S|147|2O24- 2511074800349(1), for the Assessment Year 2019 - 20, as arbitrary, ille:gal, bad in law, void-ab-initio, violative of the principles of natural justice, apart frcm being violative of Articles 14, 19(1.X9), 265 of the Constitution of lndia And Sec 148A of the lncome TaxAct, 1961, and lo consequently set aside the same in the interests of lustice. lA NO: 1 OF 20126 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit l'iled in support of the petition, the High Court may be pleased to stay all further grroceedings, including any recovery, pursuant to the order passed by the 1st Resprondent, u/s 148 of the lncorne Tex Act, 1961, dater O5.O4.2O23, .! 4l bearing DIN and Notice No.: ITBA/AST/S/ 1 48_1 120.23-24/1 05890095(1 ), for the Assessment Year 2019 - 20, pending disposal of the above Writ Petition. Counse! for, the Petitionen SRI U.SAI PRAGWAL & REP. SRt A"V-AS|VA KARNKEYA for the Respondents: SRI K.SUOHAKAR Sr.SG FOR lT l o o t Tricolour Properties Private Limited, A Private Limited Hills, Act, 1956 D.No.6-3-251 GVK mall, Kha n by its Authorized Signatory Madhav .no. 1,

#1. Assistant Commissioner of lncome Tax, Central Bhavan, Opp. LB Stadium Basheerbagh, Circle

#2. Central Board of Direct Taxes, Central Secretariat, North Bbck, New Delhi - 110001 Represented by National Faceless Assessment Cent€

#3. Commissioner O,f lncome Tax lTTowers, 10-2-3, AC Guards, (Appeals), Hyderabad bad- 11 Sth Floor, D-Block, Ffr[rXI| Petition under Article 226 of the Constitutinn of lndia prrying that in the cir-cumstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the (a)Digitally Signed Notice u/s. 148 ol the Act vide DlN & Notice No ITBA/AST/S/1 48_1 12023-241 1056737981 (1 ) dated 03.1 0.2023 issued by Respondent No. 1 in Exhibit Pl (b) Digitally signed Assessment Order uls. 147 of the Act bearing DIN & Order No. ITBA/AST/SI 1 47 I 2O2U24l 1 063795962( 1 ) dated 31 .O3.2O24 passed by Respondent No. 1 in Exhibit P2 and (c) Digitally signed Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBA/APUSI25OI2O25-261 1 08289527 4{ 1 ) dated 2'l .1 1 .2025 passed by Respondent No. 3 in Exhibit P3. 42 and all 'lther consequential actions, pehal and reoovery proceedings for being illegal, arbitrary, unlarrrrful and violative of the provisions of the lncome-i:ax Act, 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. lA NO: 1 OF 2026 Petition under Section 151 CPC praying thet in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation of and all reoo\rery and penal proceedings in pursuance of the Digitally Signe<l Notice u/s. 148 of the Act vide DIN and Notice No ITBA/AST/ 5/148-1/ 2O23-24t1O56737981(1) dated 03.1O.2023 issued by Respondent No. 1 in Exhibit P1; Erigitally signed Assessrnent Oder uls. 147 of the Act bearing DIN & Order No. ITBA/AST/SI1 47 12A23-24/1 063795962( 1 ) dated 31 fr3.2024 passed by Respondent No. 1 in Exhibit P2.and pass Digitally signed Appellate Order u/s 25O of the Act bearing DIN & Order No. ITBA/APUS/25012025-261 1082895274(1) dated 21.1'l .2025 passed by Respondent No. 3 in Exhibit P3 and pass any such other order or'oiderS ai-th6 [{oh'ble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Assessment Order and lmpugned Appella'te Order, both of which suffer from various legal and factual infirmiti,:s, would suffer ineparable hardship if coercive recovery is continued, whe:'eas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petftion. Counsel for the Petitioner: SRI SANTOSH SAGARKAPILAVAI Counset forthe Respondents: SRI N.PRAVEEN Sr. SC FOR lT r,J o l Between: Private. Limited Company i Ealapura, Road no. 1, Telangana- Madhav 43 D 1. Assistant Cornmissioner of lncome r Bhavan Opp. LB Stadium, Cental Gircle - ql

#2. National Faceless Assessrnent Centre, Room No. 4A2, llh Floor, Mavur Bhawan, Connaught Lane, Connaught Piace, New Delhi - i tOOOt.

#3. Commissioner Of tncome Tax (Appeals), Hyderabad- 11 5th Floor, DBlock, lT Towers, 10-2-3, AC Guards Hyderabaii, Tillangana S0OOO4.

#4. Central Board of Direct Taxes, Rep. by Secretrary, Certral Block, New Delhi - 110001. North S. U1io^qg{ lndia, Rep. by Secretary, Ministry of Finance, North Block, Nerrr Delhi - 110001. Petition under Article 226 ol the Constitution of tndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue writ of certiorari or any other appropriate writ or direction to set aside the. ..RESPONDENTS (a) Digitally signed Show Cause Notice uls. 274 r.w;s 270A of ttre Act vide DlN and Notice No. TBA/PNUSt27ON2o23-24t1O6gZg24g6(1) dated 3OlOgt2O24 issued by Respondent No.1 in Exhibit P2 (D Digitally signed Penalty Order uls. 27OA of the Act vide DIN and Order No. ITBA/PNL/F/27 oAt2O24-251 1068396720( 1 ) dated issued by Respondent No. 1 in Exhibit P3, and (c) Digitally signed Appellate Order u/s 250 of the Aet bearing DIN and Order No. ITBA/APUS/25O12O25-2il1A829O44O4(1) dated 22t1112O25 passed by Relspondent No. 3 in Exhibit P4. : and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the tncome-tax Act, 1961 and Articles 14 and 19(1f,g) of the Constitution of lndia. n 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 4 stay the operation of and all recovery and penal proceedings in pursuance of the 2511068396720(1) dated OOBgnOr24 issued by Respondent No. 1 in Exhibit P3 and pass Digitally signed Appeltate Order u/ s 250 of the Act bearing DIN and Order No. ITBA/APUS/2 5Ol2O25-X;l 1O82W4404(1) dated 221 1 1 12025 passed by Respondent No. 3 in Exhibit P4 and pass any such other order or orders as the Honourabler Court may deem.fit and proper in the circumstances of the case, as the Petitioner, being fastened with ftuge additions to its returned income as a result of the lmpugned Penalty Order and'lmpugned Appellate Order, and pass any such other order or orders as the Honourable'Court may deem fit and proper in the circumslances of the case, as the Petitioner, being fastened with huge additions to its retumed income as a result of the lmpugned Penalty Order and lmpugned Appr:llate Order, both of which' suffer from various legal and factual infirmities, would suffer ineparable hardship if coercive recovery is continued, whereas no pre, judice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Fetition. Counset for the Petitionen SRI'SANTOSH SAGAR KAPILAVAI Counsel for the Respondent No.l to 4: SRI N.PRAVEEN REDDY, Sr. SC FOR lT Counsel for the Respondent No.5: SRI N:B]IJJANGA RAO DEPUW SOLICITOR GENERIAL OF INDIA T:tP G] Between: Represented by its Signatory Mr. . Madhav AND

#1. Assistant Commissioner of lncome Tax, Central Circle - 3(1), Hyderabad, Aayakar Elhavan Opp. LB Stadium, Basheerbagh, Hyderabad, Telangana - 500004

#2. National f:aceless Assessment Centre, .Room No. 4O2, 4lh Floor, Mayur Bhawan, Gcnnaught Lane Oonnaught'Place, New Delhi - 110001

#3. Commissbner Of lncome Tax lT Towers, 10-2-3, AC Guards, ), bad- 11 Sth Floor, D-Block. ngana 500004 45

#4. Central Board of Direct Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi - 110O01

#5. U4r91,of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi - 110001 Petition under Article 226 ot lhe Gonstitution of lndia praying that in the circurnstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the. ...RESPONDENTS (a) Digitally signed Show Cause Notice uls- 274 r.w.s 270A of the Act vide DIN and Notice No. ITBA/PNL I S I 27 O N2O23-24l1 063796060( 1 ) (b) dated 31.03.2024 issued by Respondent No. 1 in Exhibit P2, (c) Digitally signed Penalty Order uls. 27OA of the Act vide DIN and Order No. ITBA/PNL/F/270N2024-2511O68408553(1) dated 06.09.2024 issued by Respondent No. 1 in Exhibit P3, and (d) Digitally signed Appellate Order u/s 250 of the Act bearing DIN 86 Order No. ITBA/APL/2SO I 2025-26 I 1 082904794( I ) daled 22.1 1 .2025 passed by Respondent No. 3 in Exhibit P4. and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the prcvisions of the lncome-tax Act, 1961 and Articles 14 and 19(1[g) of the Constitntion of lndia. NO: 1 OF 2026 Petition under Section 151 CPC pr4/tng that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation of and all recovery and penal prcceedings in pursuance of the 2511068408553(1) dated 06.O9.2024 issued by Respondent No. 1 in Exhibit P3 and pass Digitally signed Appellate Order u/ s 250 of the Act bearing DIN and Order No. ITBA/APL/S/2 50 12025 -26 I 1 0829047 94(1) dated 22. 1 1 .202 5 pa ssed by Respondent No. 3 in Exhibit P4 and. pass any such other order or orders as the 6 Honble Court may deern fit and proper in the circumstances of the case, as the Petitioner, beirrg fastened with huge additions to its retumed income as a resutr of the lmpugned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer ineparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenuei if recovery is stayed during the pendency of this Writ Petition. Counsel forthe Petitioner: Rl SANTOSH SAGAR KAPILAVAI Counsel forthe Respondent No.l to 4: SRI N.PRAVEEN REDDY, Sr. SC FOR lT Counsel forthe RespondentNo.S: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERIAL OF INDIA Between: Tricolour Properties Frivate Limited, A Private Limited Company incorporated under Companies Act, 1956, D.NoG3-25114, Balapura, Road no. 1, Banjara Hills Behind GVK mall, Khairatabad, Hyderabad, Telangana- 50@34 Represe, nted by'its Authorized Signatory Mr. B. Madhav ...PETITIONER AND

#1. Assistant Commissioner of lncome Tax, Central Circle - 3(1), Hyderabad, Aayakar Bhavan Opp. LB Stadium, Basheerbagh, Hyderabad, Telangana - 500004

#2. National Faceless Assessment Centre, Room No. 4O2, 4lh Floor, Mayur Bhawan, Connaughl Lane Connaught Place, New Delhi - 110001

#3. Commissioner O[ lncome Tax (Appeals), Hyderabad- 11 Sth Floor, D-Block, lT Towers, 1G2-3, AC Guads Hyderabad, Telangana 500004

#4. Central Eloard of Dired Taxes, Rep by Secretary, Central Secretariat, l,lorth Block,'Neiw Delhi - 110001

#5. Union of lndia, Rep'by Secetary, Ministry of Finance, North Block, New Delhi - 110001 Petition rrnder Article 226 of the Constitution of lndia praying that in the circumstances stated :in the affidavit filed therewith, the High Court may be pleased to issu,= Writ of Gertiorari gr any other appropriate writ or direction to set aside the. ...RESPONDENTS 47 (a) Digitally signed Show Cause Notice vls. 274 r.w.s 270A of the Act vide DIN and Notice No. ITBA/PNUS/27ON2O23-2411063797903(1 ) (b) dated 31.O3.2O24 issued by Respondent No. 1 in Exhibit P2. (c) Digitally signed Penalty Order u/s. 27OA ot the Act vide DIN and Order No. ITBA/PNUF/27ON2024-25t10683952171) dated 06.09.2024 issued by Respondent No. 1 in Exhibit P3. and (d) Digitally signed Appellate Order u/s 25O of the Act bearing DIN & Order No. 1) , dated 22.11.2025 passed by ITBA/APUS/2 5U 2025-26 I 1 Respondent No. 3 in Exhibit P4. and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, '1961 and Articles 14 and 19(1[g) of the Constitution of lndia. NO: I OF 2026 Petition under Section 151 CPC praying that in the circwnstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation of and all recovery and penal proceedings in pursuance of the 2511068395217(1) dated A6.@.2024 issued by Respondent No.'t in Exhibit P3 and pass Digitally signed Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBA/APL/S/25A12O25-2611O82904346(1 ) dated 22.1 1.2025 passed by Respondent No. 3 in Exhibit F4 and gass any such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Penalty Order and lmpugned Appellate Order, and pass any such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Penalty Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer irreparable hardship if coercive recovery is continued, whereas no 48 prejudice will be caused to the :Revenue if recovery is stayed during the<' pendency of this Writ. Petition, Counsel for ther Petitioner: SRI SANTOSH SAGAR KAPILAVAI Counsel fortNrc' Respondent No.l to 4: SRI N.PRAVEEN REDDY, Sr. SC FOR.IT DEPUW SOLICITOR GENERIAL OF INDIA Between: Santhosh Kumar Siga, S/o Anjaiah, Aged about 25 years, Occ. Farmef, ry-o Colony, lbrahimpatnam, Rangaredely H.Ns. 7-i14, Kongar Kalan, District. -Kachir AND

#1. TIre Government of {ndia, Ministry of Finance, lncome Tax Department, Rep by its Frincipal Secretary, 'New Delhi.

#2. The Princiipal Chief Comrnissioner, lncome Tax, Hyderabad. 3. The Asser; sing Officer, WARD 1 1(1 ), Hyderabad. ...PETMONER ...RESPONDENTS Petition underArticle 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court rnay be pleased to pass; an order or direction or writ in the nature of Mandarnus duly declaring the impuEned notice under Section 148 & 148A vide DIN & Notice No. ITBA/AST/51148. 1.2O22-2311042s94318(1) 06.04.2022 ITBA/AST/F1148N2O72.-2311O42539335(1) dated O5.O4.2O22, respectively and consequential: orders and proceedings, as iltegat arbitrary and against the principles of naturat iustice and consequently quash the same in the interest of fustice. lA NO: 1 OF 2026- 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 atl proceedings arising out of notice under Section 148 and 148A DIN and Notice No. ITBA/AST/51148_112022-2311042594318(1) 06.04.2022 and .,t,:, 49 ITBA/AST/F|148A|022-2311O42539335(1) dated A5.O4.2O22, respectively in the interest of justice, pendingdisposal of the writ petition. Counsel for the Petitbner: SRI P.RAMA SHARANA SHARMA Gounsel for the Respondent No.l: SRI N.BHUJANGA RAO, DEPUW SOLIC]TOR GENERAL OF INDTA Counsel for the Respondent No.2 & 3: Ms. J.SUNITHA, Sr. SC FOR lT Between: Mrs. Ustra Rani Thaduri, Housewife, R/o. H.No-3 zi Telangana Wo. Mr. Buchi Babu, aged 62 years, Occ- 7 Chelpoor, Huzurabad, Karimnagar - 5OS 122, PETITIONER AND

#1. The Assistant Commissioner of tncome Tax, Circle 1, Karimnagar, lncome Tax Office, Aaykar Bhavan, Near Natraj Theatre, Karimnagar: 505 001, Telangana.

#2. The Principal Chief Commissioner of lncome Tax, AP and TS, Hyderabad, Room No.1031, 10th Floor, C Block, lncome TaxTowers, Masab Tank, AC Guards, Hyderabad : 500 004, Telqngana

#3. Assessment Unit, lncome Tax Department, National e-Assessment Center, New Delhi, Roorn No.- 401, 2nd Floor, E-Ramp, Jawaharlal Nehru Stadium, New Delhi- 110 003.

#4. The Commissioner of tncome Tax (Appeals), National Faceless Appeat Centre, Deihi, Through the Principal Chief Commissioner of lncome Tax (NaFAC), Delhi, North Block, New Delhi - 1 10 001 .

#5. The lncome Tax Offier, Ward -2, l(anmnagar, lncome Tax Office, Aaykar Bhavan, Near Natraj Theatre, Karimnagar- 505 001, Telangana. : Petition under Article 226 of the Constitution of lndia praying that in the circurnstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ of Mandamus or any other appiropriate Writ, Order or Direction, declaration that- ...RESPONDENTS a. the Assessment Order passed by the 3rd Respondent, uls 147 r/w/s 1448 of the lncome Tax Act, 1961, dated 19.02.2024 bearing DlN.- IT8A/A5T/5114712023-2411061.1 14536(1 ), for the Assessrnent Year 2015 -16, 50 and the subse, luent rectification order passed by the 5th Respbndent, u/s 154 of {he Act, clated 26.08.2025, bearing DIN.No.=ITBA/REC|M|154|2O25- 26I1AAOA454V|3(1 ), reitifyrng the computation, b. consequential penatty order passed by the 3rd Respondent, levying penalties u/s 271(1)(e) ctf the lncome Tax Aot, 1961, dated 20.08.2024, bearing DlN.Nos- ITBAIPNUF/27'1(1)(c\|2O24-2511O67789246(1), for the Assessment Year 2015 - 16, and c. the order of the 4th Respondent dated 30.10.2025, vide DIN and Order No.. lTtsA/NFAC/Sl25Al2O2*2611O82142321(11, passed u/s 250 of the lnmme Tax Act, 1961, as a6itrary, itlegal, barred by limitation, bad in law, void-ab-initio, violative of the principles of natural justice, apart from being violative of Articles 1a, 19(1 Xg) and 265 of the Constitution ,of lndia and Sec 1 48A of the lncome Tax Act, 1961 , and corisequerltly set aside the same in the interests of justice. IANO: :l OF 2026 P€tition under Section 151 CPC praying that in the circumstances stated in ihe'afftdavit filed in support of the petition, the High Court may'be pleased to stay all further proceedings, including any recovery, pursuant to the notice r.ds 148 of the Act, dated 06.04.2022, bearing DIN and Notice No. ITBA/AST/S/1 48_112022-2311042583077(1), pending disposal of the above Writ Petition. Counself, or{he Petitioner: SRI SlNGAttl SR!i{IVAS RAO & SRI VIGHNESH ASAWA, REP. SRI A.V.A;SIVA Xanfn<eVa Counsel for thel Respondents: Ms. J.SUNITHA Sr. SC FOR lT 0 3 o .l .J,; Between: .Rami Reddy Gopireddy, S/o. Gopi Reddy Mutha Reddy, Aged about 5T trears, Occupation Business, R/o. H.No.3-127 Madhapuram Mudigbnda, Madhapuram, Khammam 507170, Telangana, lndia-PAN.BMLPG2224E, Assessment Year 20'l 8-'l 9 5l AND

#1. Assessrnent ...PETITIONER Faceless Assessrnent Room No. 4O'1, 0 003. Finance, .Delhi - 11 Centre, lncome Tax Znd Floor, E.Ramp,

#2. Ihg lncome Ta(,of:ficer, ward l. Khammam lncome Tax office, Rajeev Gunt, Raiiv Chowk,'Near Kinnerasani Theatre; Khammam Tetangana.' ' !n!pflgf^h8i?, Represent by secretary Ministry of Finance North Brock, New Delhi-l10 001 g. ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particutarrty one in the nature of WRIT OF'MANDA,MUS holding that the notice issued (JAO) by 2nd Respondent under section 148 Dated. or.04.2022 vide DIN No. ITBA/ASTIS t148-112O22-23nA42606832(1 )for the Assessment Year 201 8-1g and the consequential order passed by the 1st respondent uts. 147 read with section 144B of the' lncome-tax Act Date of order 18.01 .2024, DtN. ITBA/AST/51147 12,023-2411059840570(1 ) for the Assessment Year 201 8-1 9, as arbitrary, illegal, bad in law, void ab initio, violation of principles of naturatjustice apart frorn violation of Articles 14, 19 (1Xg) and 265 of constitution of lndia apart from being violative of provisions of section 148A and section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section 1S1A of the Act, and conseguently set aside the order passed by 1st Respondent tr/s. 147 read with sectlon 1448 of the lncome-tax Act Date of Order 18,01.2024, DlN. ITBA/AST/5114712023-2411O5984O57O(1 for the Assessment Year 2}18-19and all co nsequential proceedings pu rsua nt thereto. lA NO: 1 OF 2026 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in suppo:rt of the petition, the High Court may be pleased to stay all further proceedings including any recovery, pursuant to the order passed by the 1St Respondent u/s. 147 read with section 1 448 of the lncome-tax Act Date of Order 18.01 .2024, DtN. ITBA/AST/S/1 47t2O23-2411Os9A40570(1)for the Assessment Year 20fi-lgandstay of Demand notice under section 156 Dated. 52

18.CI1.2fi24 vide DIN No.ITBA/AST/S/1 56DA23-2411O59840674(1) for the Assessrnent Yerar 2OiB-19, pendinE disposal of the writ petitlon- Gounsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR c.ounse"l'for tho Respondent No.l & ,' REDDY; 3I'$?BH#*R .Counsel.for:the Respondent No.3: SRI N.BHUJANGA RAO, l DEPUW SOLIGITOR GENERAL OF INDI,A Behreen: The 507201 AND ...PETITIONER

#1. ASsessment Unit,, National Faceless Assessmerfi -Centr€, lncorne Tax Departmr:nt, Ministry of Finance, Roorr't No. 40'1, 2nd Floor, E-Ramp, .lawaharlal Nehru Stadium, Delhi - 110003.

#2. The lncome tax officer, Ward-1, Khammam lneome Tax ffice, Rajeev. Gunt, Raiiv C-trowk, N ea r Ki nn era san i Theatre, Kham rnarn, Telangana-Sp,70o 1 3. Unircn of lndia, Represent by its Secretary Mlnistry, of Finanee North Block, New Delhi-1 10 0O1 ..;RESPONDENTS Petition under Article 226 of the Constitution of lndia pr-ayirqg that in the circunnstances stated in the affidavit filed therewith, the F.tigh Court may be pleased to issue an appropriate wr.it, order or directisn more particularly.one in the nature.of W'rit of Mandamus holding that the order passed by 1st Respondent u/s. 747 read with section 1448 of the lT Act, d1.23.12.2024 with DIN No. |T8A/A5T/5114712024-2511071503805(1 ) for the Ay. 2019-2A, as aibitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart from violation of Articles 14, 19 (tXg) and 265 of const?tution of India apart from being violative of provi'sions of section 148A and section 149 oi the Act and also contrary to the circular issued by CBDT and provisions of section 1-51A of the Act, and cons€lquently set aside the order passed by 1st Respondent u/s 147 read with ser:tion 1448 of the lT Act, dt. 23.12.2A24 with DIN No. -i 53 ITBA/AST/sl7'4v12o24-2511o71503805(1) for the Ay. 2a1g-m and atl con segu entia I'p roceedi ngs pu rsuant the re to. lA NO: 1 OF 2026 Petition under Section 151 CPC praying that in the circurnstances stated in the affidavit filed in support of the petition, the High Court may.be pfeased to stay- att further- proceedings, including any recovery, pursuant to the order pqgsed by the 1St Respondent u/s 147 read with section 1448 of the tT Act, dt l' 23.12,.2A24 with DIN No.,ITBA/AST/S/1 4712024-2511071503805(1[o.r: the A,y. 2A19.20, pending disposal of the writ petition. : . ... .: :' , . Counsel for tle Petitioner: SRI THANNERU CHATTANYA KUMAR Counsel for the Respondent No.l & 2: SRt K.SUDHAKAR REDDY, Sr. SC FOR lT Couns-el for the Respondent No.3: SRI N.BHUJANGA RAO, DEPUTY SOLiCITOR GENERAL OF ]NDIA Between: Trigqbqr Properties Private Limited, A Private Limited Cornpany incorporated urder_comrynrgg {ct, 1956 D.No.6-3-25114, Balapura, Ro'ad no. 1, fJaniara Hitls Behind GVK matl, Kh_airatabad, Hyderabad, TelarBana-' s0ob34 Represented by its Authorized Signatory Mr. B. Madhav ...PETITIONER trND

#1. Assistant Commissioner of lncome Tax, Central Circte - 3(t), Hyderabad, Sgygf1 Bhavan Opp. LB Stadium, Basheerbagh, Hyderabdd,'Teiangana - 500004

#2. National Faceless Assessment centre, Room No 402, 4th Floor, Mly, rt Bhawan, Connaught Lane Connaught Plice, New Delhi- i10OO1

#3. Cornmissioner Of lncome Tax lT Towers , 1O-2-3, AC Guards (Appeals), Hyderabad-'11 Sth Floor, D-Block, Hyderabad, Telangana 500004

#4. Central Board 9[ Direct Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi - 110001

#5. uryq of India, Rep by secretary, Ministry of Finance, North Block, New Delhi - 1 10001 ...RESPONDENTS 54 Petition under Article 226 of the Constitution of lndia praying that in the - circumstances stated in the affid, avit, frled'therewith, the High Court may be pleased to issue Writ of Certiorari or anyother appropriate writ or direction to set aslde the (a) Digitatly signed Show Cause ,Notice uls- 274 r.w.s 270A of the Act vide DIN and Notice No ITBA/PNUSI27OAI2O23'2411O63798025(1) dated 31.Ag.2O24 issued by Resp, ondent No. 1 in Exhibit P2 (b) Digitatly signed Penalty Order u/s. 270A of the Act vide DIN & Order No ITBA/PNL |F\27ON2O24-:2511O6839480O(1) dated ffi.W.2024 issued by Respondent No. 1 in Exhibit P3 and (c) Digitally sigr.red Appellate Order u/s 250,of the"-Act bearing DIN and Order No. ITBA/APL13125A12A25-2611084013734 (1) dated 23.12.2A25 passed by Respondent No. 3 in Exhibit P4. and all other consequential actions, penal and recovsy proceedings for being illegal, arbitrarlr, unlavvful and violative of the prwisioRs of the lncome-tax Act, 1961 and Articles 14 and t 9(1 Xg) of the Constitution of lndia. lA NO: 1 OF 2026 Petition lnder Section 151 CPC praying that in the circunrstances stated in the affidavit filed in support of the petition, the Hig:h Court may be pleased to stay the operation of and all recovery and penal proceedings in pursuance of the Digitally signecl Penalty Order vide DIN and Order No.|TBA/PNUF/27OA12O24- 25l 1068394800(1) dated 06.09.2024 issued'by Respondent No. 1 in Exhibit P3 and pass Digit; ally signed Appellate Order uls 250 of the Act bearing DIN and Order No. ITB,A/APL/S/25O12O25-2611O84O19734 (1 ) dated-23-12-2025 passed by Respondent No. 3 in Exhibit P4 and pass any such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Penalty Order and lmpugned Appellate Order, and pass any such other order or orders as the Hon'ble Courl may deem fit and proper in the circumstances of the case. as the Petitioner, being fastened with huge *( 55 additions to its rettrmed income as a result of the lmpugned Penalty Order and lmpr.rgned Appettate Gder, both of which suffer from various legal and factual infimities, would suffer irreparable hardship if coercive recovery is continued. whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. counsel for the Petitioner: sRl DHANWAMTRI AMANTH RESPRESilNG SANTOS}I SAGAR KAPILAVAI Gounset for the Respondent No.l to 4: sRl N.PRAVEEN REDDY; Sn SC FoR lT .:-'...:.., . . Gounsel for the Respondent No.5: SRI N.BHUJANGA RAO, DEPUW SOLrcTTOR GENER]AL OF INDIA Between: Tricolour Properties Private Limited, A Private Limited Company incorporated under Companieg..4ct, 1956 D.No.6-3-25114, Balapura, Ro'ad no. t, ilanjam Hills, behind GVK mall, Khairatabad, Hyderabad, Telangana-' S00034 Represented by its Director/Authorized Signaiory Mr. B. Madhd PETITIONER AND.

#1. Assistant commissioner of lncome Tax central Circle - 3(1), Hyderabad, 4gy{q, Bhavan Opp. LB Stadium, Basheerbagh, Hyderabdd,'Tieiangana - 500004

#2. National Faceless Assessment centre, Room No. 402, 4th Ftoor, Mayur Bhawan, Connaught Lane Connaught Place, New Delhi- 110@1

#3. Commissioner of lncome Tax (Appeals), Hyderabad- 11 sttr Floor, DBlock, lT Towers, lO-2-3, AC Guards Hyderabaii, T6hngana 500O04

#4. Central Board of Direct Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi -110001

5.: Union of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi -110001 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the ...RE.SPONDENTS 56 (a) Show causer notice uls. 274 r.w.s. 271(1)(c) bearing DIN and Notice No.lTBA/ - PNUS/271(1Xcll2O23-2414O63797899(1) dated 31.03.2024 passed by Respondent Nc,. 1 in Exhibit P2. (b) Digitally Signed Penalty Order u/s. 27'l(1\(cl d the Act bearing DIN and Order No. ITBA/PNUI=I 271(11 (c) I 2024-251 1068397980('1) dated 06.O9.2024 passed by Respondent No. 1 in Exhibit P3. (c) Digitally Siglned Ex-parte Appeal Order passed u/s. 250 bearing No. ITBA APUS/250/2025- 2611084OO3784 (1) daled.23-1212025 is marked and enclosed as Exhibit P4. and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary', unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articft:s 14 and 19(1)(g) of the Constitution of lndia. lA NO: I OF 2026 Petition under Section 151 CPC pia'Ving that in the circumstances stated in the affidavit 1lled in support of the petition, the High Court may be pleased to stay the operalion of and all recovery And penal proceedings in pursuance of Digitally Signecl Penalty Order u/s. 271(1)(c) of the Act bearing DIN and Order No. ITBA/PNLI Fl 271(11 (cll2024- 25l 106839798O(1) dated 06.09.2024 issued by Respondent No.1 in Exhibit P3 and Digritally Signed Ex-parte Appeal Order passed u/s. 250 bearing No. ITBA/APLlSl25OnA?5-26,1 1084003784 (1) dated. 23-12-2025 in E:xhibit P4 and pass any suoh other order or orders as the Hon'ble Court may der:m fit and proper in the circumstances of the case, as the Petitioner, bein1tr fastened with huge additions to its returned inbome as a result of the lmpugned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer irreparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel for the Petitioner: SRI SANTOSH SAGAR KAPILAVAI Counsel for the Respondent No.l to 4: SRI N.PRAVEEN REDDY, Sr. SC FOR lT $ 57 Counsel forthe Respondent No.5: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERIAL OF INDIA G Between: Tricolour Properties Private Limited, A Private Limited Company inco under Companies Act, 1956 D.No.6-3-25'114, Batapura, Robd no. 1, Hills, behind GVK mall; Khairatabad, Hyderabad, Telangana- Represented by its Authorized Signatory Mr. B. Madhav rporated Banjara 500034 ..;PETITIONER AND

#1. Assistant Commissioner of lncome Tax, Central Circle - 3(1), Hrdera 4ayakar Bhavan Opp. LB Stadiurn, Basheerbagh, HyderahiO,'teianga 50m04 bad, na-

#2. National Faceless Assessment Centre, Room No. N2, 4fri Floor, Mayur Bhawan, Connaught Lane Connaught Place, Nerr Delhi - 110001

#3. Commissioner Of lncome Tax (Appeals),, Hyderabad- 11 Sfir Floor, D-Block, lTTowers, 10-2-3, AC Guards Hyderabad, Telangana 500004

#4. Central Board of Direct Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi - 110001

#5. Union of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi - 110001 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the l-ligh Gourt may be pleased to issue Writ of Cediorari or any other appropriate writ or direction to set aside the. ...RESPONDENTS (a) Show cause notice uls. 274 r.w.s. 271(1)(c) bearing DIN and Notice No.lTBA/PNL/51271(1)(cll2o23-2411063797721(lldated 3'1.O3.2O24 passed by Respondent No. 1 in Exhibit P2. (b) Digitally Signed Penalty Order u/s. 271(1)(c) of the Act bearing DIN and Order No. ITBA/PNUF/271(11(c[2O24-2511068397978(1) dated 06.09.2024 passed by Respondent No. 1 in Exhibil P3. (c) Digitally Signed Ex-parte Appeal Order passed u/s. 250 bearing No. ITBA/APL/S/25O12O25-2611OUO01137 (1) dated 23nA2025 is marked and enclosed as Exhibit P4. 58 and all other consequential actions, penal and recovery proceedings for being ilkrgal, abitrary. unlawful and violative of the provisions of the lncome-tax Act, 1961 and. Articles 1,4 and 19(1Xg) of the Constitution of lndia. lA NO: 1 OF 20 Petition under Section 151 CPC praying that in the circumstances stated in-the-affidavit-f1ed-i+supportoFthe-petition;-tfieltighGourt-maybe-pleased{o -.----------.-.- stay the operation of and all recovery and penal proceedings in pursuance of Digitally Signecl Penalty @er u/s. 271(1Xc) of the Act bearing DIN and Order No. ITBA/PNUF 127 1 (1 )(cl2o24-251168397978(1 ) dated 06.09.2024 issued by Respondent No. 1 in Exhibit P3 and Digitaliy Signed Ex-parte Appeal Order passed u/s. 250 bearing No. ITB)VAPUS/25O12O25-261 1084001 137 (1) dated 2311212025 in E:xhibit P4 and pass any such other order or orders as the Hon'ble Court may der:m fit and prcper in the circumstances of the case, as the Petitioner, bein,g fastened with huge additions to its returned income as a result of the lmpugnr>d Assessment Order and lmpugned Appellate Order, both of which suffer frrm various legal and factual infirmities, would suffer irreparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed, during the pendency of this Writ Petition. Counsel for the, Petitbner: SRIDHAiIWAMTRI Af{ANTH RESPRESTING SRI SANTOSH SAGAR KAPILAYAI Counsel for the, Respondent No.f to 4: Sl N.PRAVEEN REDDY, Sr. SC FOR lT Counsel for the Respondentt{o.5: SRI N.BHUJANGA RAO, ffiPtJIY SOLICITOR GENER]AL OF INDIA o 1 Between: Mohamm, ed Hidayathuddin, S/o. Mohammed Shafiuddin Aged about 7?years, Occ- Business, Fi/o- 10-3-73P. 197/3rt Rahim Mlla, Viiay NagarColony Hyderabad 500057 Telangana, lndia PAN-AEFPH180OJ, Assessment Year- 2020-21 ...PETITIONER AND A 59 1 . Assessment Unit, National Facelsss Assessment Cente, lncome Tax finance, Roorn No. 4O1, Znd Floor, E-Ramp, , Delhi- 110 003. Ministry of Nehru Stadium

#2. The lncome Tax Sy.No.6(P) of Sertingampally (M), Ward bad/ opp. re Towers, Gardens.

#3. pnio4 of lndia, Represent by Secretary Ministry of Finance North Block, Netrr Delhi-1'lO OOI Petition under Article 26 ot lhe CcinStitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of WRIT OF MANDAMUS holding that the notice issued by the 2nd Respondent u/s. 14A of the Act, dt.15.,04.2024 with DIN No- IT8A/A5T/5/148_112024-2511064084976(1) for the Ay. 2O2O-2'1, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice apart from violative of Articles 14, 19 (1)(g) and 265 of constitution of lndia, apart from being violative of provisions of section 1ul8A and section 149 of the lncome Tax Act and also contrary to the circular issued by CBDT and provisions of section 151A of the Act, and consequently set aside the order passed by 2nd Respondent u/s. 148 of the Act, dt.15.O4.2024 with DIN No- ITBA/AST/S/148_112024-2511064084976(1) for the Ay. 2A2O-21 and all consequential proceedings pursuant thereto. lA NO: I OF 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 2nd Respondent u/s. 148 of the Act, dt.15.O4.2O24 with DIN No- ITBA/AST/S/148 _112024-2511064084976(1[or the Ay. 2O2O-21, pending disposal of the writ petition. Counsel forthe Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel forthe Respondent No.l & 2: Ms. B.SAPNA RED Sr. SC FOR lT 60 Counsel forthe Respondent'No.3: SRI N.BHUJANGA RAO, DEPUW SOLIGITOR GENERAL OF INDIA Between: Tricolour Properties"Private Limited, A Private Lirnited Company incorporated under Cc'mpanies Act, 1956 D.No.6-3-25114, Balapura, Road no. t, Baniara Hills Bethind GVK mqll; Khairatabad, Hyderabad, Telangana- 500034 Represented by its Authorized Signatory Mr. B. Madhav ..PETITIONER AND

#1. Assistant Commissioner of lnqome Tax Central Circte - 3(1), Hyderabad, Aayakar Bhavan Opp. LB Stadiurn, Basheerbagh, Hyderabdd, Teiangana - 500004

#2. National Facetess Assessment Centre, Room No 402, 4th Floor, Mayrr Bhawan, Connaught Lane Connaught Place, l{ew Delhi - 110001

#3. Commissioner Of lnconre Tax (Appeals), Hyderabad- 11 sth Floor, D-Block, lT Towen;, 10-2-3, AC Guards Hyderabad, Telangana 500004

#4. Central Eioard oJ Dlt'cct Taxes, Rep by Secretary, Central Secretariat, North' Block, Nerw Delhi -'11000{

#5. Union of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi - 110001 ...RESPONDENTS Petition rrnder Arttcle 226 of the Constitution of lndia praying that in the circumstaRces stated 'in the affidavit filed therewith, the High Court may be pleased to issur: Writ of Certiorari or any other appropriate writ or direction to set aside the (a) Digitally signed Show Cause Notice uls. 274 r.w.s 270A of the Act vide DIN & Notice, No ITBA/PNLlSl2TOAl?i23-2411063752408(1) dated 31.O3.2O',24 issuedby Respondent No. 1 in Exhibit P2 (b)Digitally :;igned Penalty Order uls.2TOAof the Act vide DIN and Order No ITBA/PN|JF|27ON2O24-25|1068397612(1) dated 06.09.2024 issued by Respondent No. 1 in Exhibit P3 and (c) Digitally r;igned Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBA/APL/S/25O 12025-2611 0829048 42(1 | d ated 22.1 1 .2025 passed by Respond,=nt No. 3 in Exhibit P4. 6l and all other consequentid actions, penal and recovery prcceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. IANO 1oF20.26 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 the operation ofand all recovery and penal proceedings in pursuance of the 251106839761 2(1) dated 06.09.2024 issued by Respondent No. 1 in Exhibit P3 and pass Digitally signed Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBA/APUS/25O12O25- 2611082904842(1) dated 22.11 .2025 passed by Respondent No. 3 in Exhibit P4 and pass any such other order or orders as the Honble Court may deem ft and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the lmpugned Assessment Order and lmpugned Appellate Order. both of which suffer from various legal and fac{ual infirmities, would suffer irreparable hardship if coercive recrvery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel forthe Petitioner: SRI SANTOSII SAGAR KAPILAVA| Counse! forthe Respondent lrlo.1 to 4: SRI N.PRAVEEN REDDY, Sr. SC FOR tT Counsel forthe Respondent No.S: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERIAL OF INDIA Between: Smt. Karuna Shetty, Wo. Sri Shetty Occupation. House Wife, 11-23-167 Warangal - 506002. Kishan Rao, Aged about 66 8, Desaipet Road, Ganesh years, Nagar, AND 1 . Assessment Unit, National Faceless Assessment Centre, lncome Tax Department, Ministry of Finance, Room No. 401 , 2nd Floor, E-Ramp, Jawaharlal Nehru Stadium, Delhi -'110 O03. ...PETITIONER 62 'l

#2. The ln@me Tax Officer, Ward - 1, lncome Tax Ofltce, 1-8610, Srd Floor, Mayuri (hmplex, Opp. TSNPDCL Elftawan, Nakkalagutta, Hanamkonda, Wamngal -506001. ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High CouFt may be pleased to pass an order or direction, especially one in the nature of WRIT OF MANDAMUS .hoEing that the notice dated O7.O}.2O24 issued by 2nd Respondent trnder section 148 of the Act fwith DIN and NOTICE No.ITBAIAST/S1148-112O23-2411O62189028(1)I as being without jurisdiction, arbitrary, iltega{, bad in law, void ab initio, apart from being violative of provisions of section 1,zl8.A and section 149 of the Act and also contrary to the eircutar issued by GBDI and provisions of section 151A of the Act, and consequently set aside the nolhe under section 148 dated 07.03.2024, the assessment order passed by 1st Respondent under section 147 r.w.s 144 r.w.s'1448 of the Act, dl-2O.O2-2O25, Penalty orders passed u/s.272A(1Xd) and u/s.271AACdl) of the Act, dt.19O8.2{l% an;d 21 .O8.2O25, respectively for asst. year 2017-18. lA NO: 1OF 2026 Petition r:nder 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 collection of tbx and penalty demand raised by 1st Respondent forthe Ay.2O17-18, pending disposal of the writ petition. Counsel for thh Petitioner: Ms.ICPRABHABATI LEARNED COIJNSEL APP,f,ARS FORSRI A.V.RAGHU RAM Counsel fortheRespondenG: Ms.8Ol(ARO SAPNA REDDY, Sr. SC FOR.IT e 3 Il Between: Tricolour Poperties Private Limited, A Private Limited Company incorporated under Companies Act, 1956, D.No.6-3-25114, Balapura, Road no.1, Baqiana Hills, behind GVK mall, Khairatabad, Hyderabad, Telangana- 500034 Represented by its Authorized Signatory, Mr. B. Madhav ..;PETITIONER 6t nIIID

#1. Assistant Commissioner of Bhavan, opp. LB lncome Tax, Central Circle - 3(1), Hyderabad Stadium Basheerbagh, ffierabail,' Telangana -

#2. National Faceless Centre, Room No. 2102, 4th Floor, Mayur Bhawan, Connaught Lane Connaught Place, New Delhi - 11(X)01

#3. Commissioner Of lncome Tax lT Towers, 10-2-3, AC Guards 11 Sth Floor, D-Block, 5000(N

#4. Centrat Board of Direci Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi- 110001

#5. Union of lndia, Rep by - 11m01 Ministry of Finance, North Block, New Delhi Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to. issue Writ of Certiorari or any other appropriate writ or direction to set aside the. (a)Digitally Signed Show Cause Notice u/s. 2V4 r.w.s.271AAB bearing DIN and Notice No. TBA/PNUS/271AABl2O23-24l1063753320(1) dated 31 .O3.2O24 passed by Respondent No. 1 in Exhibit P2. (b)Digitally Signed Penalty Order u/s. 271AAB of the Act bearing DIN and Order No. ITBA/PN UFl2 7 1 AAB I 2024-25/1 0684085 56( 1 ) d ated 06.09.2024 passed by Respondent No. I in Exhibit P3. (c) Digitally Signed Ex-parte Appeal Order passed u/s. 250 bearing No. ITBA'/APUS/25O12025-2A[082929812(1) dated 24.1 1.2025 is marked and enclosed as Exhibit P4. and all other consequential actionsr penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1Xd) of the Constitution of lndia. 1()F Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in suppoil of the petition, the High Court may be pleased to 64 stay the operation of and all recovery and penal proceedings in purcuance of Digitally Signed Penalty Order u/s. 271AAB of the Act'bearing DIN-and Order No. ITBA/PNUFI27'lAABl2O24-25/1068408556(1) dated 06:09.2024 issued by No,. 1 in Exhibit P2 and pass any such other order or orders as the Hon'ble Court rnay deem fit and proper in the circumstaoc€s rof the case, as the Petitioner, beinrg fastened with huge additions to its retumed income as a result of the lmptrgned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer ireparable hardship if coercive recovery is continued, whereas no preiudice will be caused to the RevEnue if recovery is stayed during the pendency of this Writ Petition. Gounsel for the PEtitioner: SRI Counselforthe Reqrondent No.l to 4: SRI N.PRAVEEN Sr. SCEOR.IT n Gounselforthe Respondent No.S: SRI N.BHUJANGA RAO DEPUW SOLICITOR GENERIAL OF INBIA n :l I Private Limited, Plot Sreenivasulu D I Kamalapuri Colony 500073, Telangana, lndia PAN.AAECN3034E, Assessment Year. Rep. Aged No 188 S/o No t5-16 AND 1. Unit, National Faceless Assessment Centre. lnmme Tax Ministry of Finance, Room No. 401, 2id Floor, E.Rarnp, harlal Nehru Stadium, Delhi - 110 003.

#2. The lncorne'tax offrcer, Ward 16(1), Hyderabad/ I T Tower, Accuards, Masab Tank, Hylerabad, Telangana

#3. Union of llndia, Represent by Secretary, Ministry of Finance North'Block, Nelv Delhi-110O01 ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of WRIT OF MANDAMUS holding that the notice issued (JAO) by 65 2ndRespondent under section 148 Dated. 12.04,2022 vile DIN No. ITBA/AST/S/148_1l/2022-2311042705310(1fior the Assessment Year 201S..l6and the consequential order passed by the 1st respondent uls. 141 r.w.s 144 read with section 144Bof the lncome-tax Act Date of Order 02.01.2024, DlN. ITBA/AST/S/1 47 12023.241 1 059287 512(1 ) for the Assessment Year 20i S-1 6, as arbitrary illegal, bad in laq rcid ab initio, violation of principles of natural justice apartfrorn violation of Articles 14, 19 (1)(g) and 265 of constitution of lndia apart from being violative of provisions of section 148Aand section 149 of the Act and also contrary to the circutar issued by CBDT and provisions of section:.l51A of: the Act, and consequently set aside the order passed by 1st Respondent u/s. 147.r.w.s '144 read with section 144Bot the lncome-tax Act Date, of Order O2.O1 .2024, DlN. ITBA/AST lsl 1 47 12023-24t 1 059287 512(1) f or the Assessment Year 2015-'l6and all consequential proceedings pursuant thereto. 1 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 lst Respondent uls. 147 r.w.s 144 read with section 144Bol the lncome- tax Act Date of OrderO2.O1.2024, DlN. ITBA/AST/S/14712023-2411O59287512(1) for the Assessment Year 2015- 16and stay of Demand notice under section 156 Dated.O2.O1.2024vide DIN No. ITBA/AST/S/15612O23-24t1059287605(1)forthe Assessment Year 2015-16, pending disposal of the writ petition. Counsel for the Petitioner: MT.B.MURALIDUOR APPEANSSRI THANNERU Counsel forthe kspondent No.l & 2: SRI.K.SUDHAKAR REDDY, Sr. SC FOR lT Counsel forthe Respondent No.3: SRI N.BHUJANGA RAO DEPUW SOLICITOR GENERAL OF INDIA 66 o Mr. Mohammed Azeemuddin Azam, S/o. Mr. Mohammed Qameruddin, Aged about 57 years, Pillar No.258, Attaput Hvd Business, 6-10-128120ru4, Quadri Hills, -500048 D

#1. Assessment Unit, National Faceless Assesement Departmrrnt, Ministry of Finance, Room No. N|, 2tid Jawaharlal Nehru Stadium, Delhi -110 003. lncome Tax E-Ramp,

#2. The lncome Tax Officer, Ward - 9(1), 1.T. Towers, A.C. Guards, Masabtank, Hyderabad - 500004. Petition r-rnder Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High'Court may be pleased to pass an order or direction, especially one in the nature of WRIT OF MANDAMUS holding that the noticed daled 27.84.2022 issued .by 2nd 'Respondent under section 148 of lhe. Act [with DIN and NOTICE No.iTBA/AST/51148_1I2O22-23I1O42871783(1)l as being without jurisdiction, ry, illegal, bad in law, void ab initio, apart from being violative of pr.ovisions of section 148,\ and section 149 of the Act and also contrary to the circular issued by CBD1- and provisions of section 151A of the Act, and consequently set aside the notic,e under section 148 dated 27.A4.2022, the assessrnent order passed by 1"t Respondent under section 147 r.w"s 1zt4 r.w.s 1448 of the Act, dl.'12.92.2o24, Penalty orders passed uls.272A(1Kd) and u/s.271AAC(1) of the Act, dt.14.08.2024 and 21.O8.2024, respectively for asst. yeai 201 &19. 1A NO: 1OF m'26 Petition under Section 151 CPC praying ,that in the circumstances stated in the affidavit liled in support of the petition, the High Gourt may be pleased to stay collection of tax & penalty- demand raised by 'lst Respondent for the Ay.20la- 19, pending disposal of the writ petition. Counsel for the Petitioner: Ms.PRABTABATI LEARNED COUNSEL APPEARS SRI A.V.RAGHTI RAM Gounsel for the Respondents: sRl K.SUDHAKAR REDDY, sr. sG FoR lr 67 Between: Tricolour Properties Private Limited, A Private Limited Company incorporated un-der Gompanies Act, 1956 D.No.6-3-25114, Balapura, Ro:ad no. 1, Baniara Hills, betin{. qVK mal! Khairatabad, Hyderabad, Telang4na-- S0O03t Rqpresented by its Authorized Signatory Mr. B. Madhav .PETTTIONER AND

#1. nssistant comrnissioner of lncome Tax, central circle - fl1), Hyderabad Aay?far Bhavan, Opp. LB Stadium Basheerbagh, Hyderabatl,'TelbnEana - 5000(M

#2. 'Gentral Board of Direct Taxes, Central Secretariat, North Blcck, New Delhi - 110001 Represented by National Faceless Assessment Centre

#3. Qgmmissioner Of lncome Tax, (Appeals), Hyderabad- lT Towers, lO-2-3, AC Guards, Hyderabad, Telangana 11 5th Floor, D-Bloch 500004 ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the. (a) Digitally Signed Notice u/s. 148 of the Act vide DIN and Notice No. ITBA/AST/$1148-1120:23-2411056737986(1) dated 03.10.2023 issued by Respondent No. f in Exhibit Pl, (b) Digitally signed Assessment Order u/s. 1 47 ot the Act bearing DIN and Order No. ITBI/AST/S114712O23-241 1063-735062 (1) dated 31.03.2024 passed by Respondent No. 1 in Exhibit P2, and (c) Digitally signed Appellate Order u/s 25O of the Act bearing DtN and Order No. ITBA/APUS l25aln25-26t1o8289601 1(1 ) dated 21 .11 .2025 passed by Respondent No. 3 in Exhibit P3. and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. lA NO: 2 OF ZOZf 6E Petition under Section 151 CPC pra ing that in the circumstiances stated in the affidavit fitad in support of the petition, the High Court may be pleased to stay the operation of and all recovery and penal proceedings in pursriance of the Digitally Signecl Notice u/s'. 148 of the Act vide DtN and Notie No. ITBA/AST/ st14}.1t2123:2:41',t956737s86(1) -d,alqd- !3.-192023-icsu-e. !--DJ..eesp_q!dcnt Ns. 1 in Exhibit P1, E,igitally signed Assessment Order uls. 147 of the Act bearing DIN and Oid-e r -Nct. I T-BAIASTTSI 14 passed by Respondent No. 1 in Exhibit P2 and pass Digitally signed Appellate Order u/s 250 of the Act bearing DIN and .Order No. No. ITBA/APL/S/2 5Ol2O25- 261108289601 1(1) dated 21.11.2A25 passed, by Respondent No. 3 in Exhibit P3 and pass any s;uch other order or orders as the Honble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a res-tllt of the linpugned Assessment Order and lmptrgned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer irregarable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel forther Petitioner: SRI SANTOSH SAGAR ]({Pll-e l Couhsel forther Respondents: SRI N.PRAVEEN REDDY, Sr. SC FOR lT Betv$een: Sri Venkrteswara Rao Tammineni, S/o. Sfi Laxrnnarasaiah Tammineni, Aged about 62 years, Occupation. Business, 8-2-94, Balaji lGgar, Khammam - 507001. AND

#1. The lncorne Tax Officer, Ward -'1, lnoorne Tax Ofiice, Rajeev Gunt, Rajiv Chowk, Near Kinnerasani Theatre, Khammam - 507ff)1.

#2. Assessmr:nt Unit, National Facebss Assessmenl Centre, lncome Tax Departmernt, Ministry of Finance, Room No. 401, 2nd Floor, E-Ramp, Jawaharlal Nehru Stadium, Delhi - 110 003. .,.PETMONER ...RESPONDENTS Fri 69 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the Htgh Court may be phased to pass an order or direction, especially one in the nature of WRTT OF MANDAMUS holding thatthe notice dated 28.03.2023 issued by lSt Respondent under section 148 ot the Act with DIN and NOTTCE No.ITBA/ASTISfi4B_1lZO22- 2311'051444745(1) as being without jurisdiction, arbitrary, itlegal" bad in law, void ab initio, apart from being violative of provisions of section 148A and section 149 of the Act and also contrary to the circular issued by CBDT and proVisions of seetion 151A of the Act, and consequentty set aside the notice under, section !48 , dated 28.03.2023, the assessment order passed by 1st Respondent under section 147 r.w.s 144 of the Act, dt.15.03.2O24, Penalty orders passed by 2nd Respondent uts.271F, uls.271(1Xb) and u/s.271(1)(c) of the Act dt.09.og.2a24, fi.O9.2024 and fi.Ag.2024, respectivety for asst. year 2O1,6-17. lA NO: I OF 2026 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 collection of tax and penalty demands raised by 1st and 2nd Respondents for the Ay.2016-17, pending disposal of the writ petition. GOUNSEI for the Petitioner: Ms.K.PRABHABATI LEARNED COU}I$EL APPEOR SRI AV.RAGHU RAM Counsel for the Respondents: SRI K.SUDHAKAR REDDY, Sr. SC FOR lT Between: Sri Nagunoori Darnodar, S/o. Sri Nagunoori Venkata Lingaiah, Aged about 52 years, Occupation. Private Service, Permanent Address. 368 S Crown CT, Palatine, lL - 60074, USA. Temporary/Present Address. 35-6-243, Pragathi Nagar Colony, Gopalapuram, Hanamkonda, Warangal - 506001. - AND

#1. The lncome Tax Officer, Ward - 1, lncome Tax Office, 1-8:610,3rd Floor, .\I.ayuri Complex, Opp. .TSNPDCL Bhawan, Nakkalagutth, Hanamkonda, Warangal - 506001. ...PETITIONER 70

#2. Assessment Unit, National Faoeless Assessment Department, Ministry of Finanoe, Room No. 401 Jawaharl; al Nehru Stadium, Ddhi . 110 003; Centre, lncome Tax 2nd Floor, E-Ramp, ...RESPONDENTS Petition under Artiole 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to pas:; an order or dlrection, espgcialty one in the nature of WRIT OF MANDAMUS holding that the notice dated 0A.03.2024 issued by lSt Respondent under section 148 of the Act (ri4th DIN and'NOTICE No.ITBA/AST/S t148-1t2023- 2411062249687(1)) as being without jurisdic{ion, arbitrary, illegal, bad in law, void ab initio, apart I'rom being violative of provisions ofsection 148A and section 149 of the Act and also contrary to the eircular issued by CBDT and provisions of section 't 51A ol the Act, and consegrrently set aside the notice under section 148 dated 08.03.2Cr24, the assessment order passed by 1st Respondent under section 147 r.\^,.s 144 of the Act, dt.19.03.2025,'Penalty orders passed by 2nd Respondent ui:;.272A(11(d) and uls.271.AAC(1) of the Act, dt.15.09.2025 and 24.09.2025, respectively for asst. year 2O2A-21. tA NO: 1 OF 20'76, Petition under Section 151 CPC praylng that in the circumstances stated in the affidavit f iled in support of the petition, fte tligh Court may be pleased to stay collection of tax & penalty demandi raised by 1st and 2nd Respondents for the Ay.2020- 21, pending disposal of the writ petition. Gounsel for the Petitioner: Ms.K.FRABHABATI LEARED COUNSEL APPEAR FOR SRI A.V.RAGHU RAM Counset for the Respondents: Ms. BOI(ARO SAPNA REDDY, Sr. SC FOR lT o I] Between: Jallapurarn Narsing Sridhar, S/o. Ja years, Occ. Private Services, Block K, Moosapet, Hyderabad 50001 8. llapuram Nansing Rao Aged about 52 Flat 209, Rainbow Vistas Rock Garden, ...PETITIONER AND ,h; i. 1 'lt 'lt. National Faceless Assessment No.401, 2nd Floor, E-Ramp, Jawaharlal of Finance, Room De']hi-l10003.

#2. The lncome Tax Officer:, Ward- 1,0(1), Hyderabill, lT Tower, AC Guards, Ernail. Masab T?qI,- ^. Flyderabad ' : : Hyderabad.lTOl0.l@incometax.gov.in, 500m4, TS. ,, ...RESPONDENTS Petition under Article 226 of the Constitutirin of lndia prayring that in the circumstances stated in the affidavit filed thereWith, the High Court may be pleased to issue a writ, order or direction, morg particulqrly one in the nature of Writ of Mandamus, declaring the notice u/S 148:c"*"ai ,'r.o3,2023 vide DIN No. ITBA/AST/S1148_112022-2311050931681(1) issued by tfie Jurisd, ictional Assessing Officer (JAO) i.e. Respondent'No.2 instead of Faceless Assessing Officer (FAO) i.e. Respondent No.1 for A.Y.2016-17.as void, illegal and contrary to the provisions of lncome-tax Act and contrary to the Constitutional Provisions . , i. . . : :1.i,' . ' .....,. .i ' '. '; l ' including Principles of Natural Justice. !A'NO: 1 OF 2026 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 pursuant to the notice uls '148 dated 18,03.2O23 vide DNN No. ITBA/AST/51148_112022-2311050931681(1) issued by the, Jurisdictional Assessing Officer (JAO) i.e. Respondent No.2 instead of Faceless Assessing Officer (FAO) i.e. Respondent No.1 for A.Y. 2016-17, pending disposal of the subject writ petition. Gounsel for the Petitioner: SRI DUNDI, MANMOHAN REPRESTING SRI T.V.L.NARASIMHA RAO Counsel for the Respondents: Ms. BOI(ARO SAPNA REDDYi Sr. SC FOR lT Between: Syed Abdul Bari, Syed Abdul Subhan Aged about 12-1-923 E 3rd Floor Sk Noble Plaza Flat no Hyderabad 500001, Telangana, Street 16, Building 111, 3 Floor, Rep by Special Power of Attorney Holder Syed AMul Suhhan, S/o.Syed Omer, aged about 76 years, Occ Business, R/o 94-13 5lEl3l2 Ground floor, Occ Softvvare Ri/o T 4,. 49 12 Valli colony, tolichoraAi, Golconda, Telangana, lndia PAN:FYZPS9383G, - Assessment Y€ar 2O2O-21 .PETITIONER AND

#1. Assessment Unit, 'l{ational Faoeless Assessrnent Centre, lncome Tax Department, Ministry of ,Finance,'Room No. 4A1, 2nd Floor, E-Ramp, Jawaharlat Nehru Stadiurn, Delhi 110 003.

#2. The lncorme tax offieer (lTO), (lNT T-ARNF2, HYD Aaykar Bhawan, Opposite Lb Stad i ur m, ;BasheerBagh, Hyderabad-S0OO04, Tela ng a n a :

#3. Union of lndia, Represent by Seeretary Ministry of Finance North Block, New Delhi-l1C) OO1 ...RESPONDENTS Petition trnder Article 2K of the'Consiitution of lndia praying that in the circumstances stated in the ffidavitrfiled therewith, the High Court may be pleased to issue an apprqprtate wrtt, order or direction more particularly one in the nature of WRIT OF MANDAMT S holding that the notice issued (JAO) by 2nd Respondent r;nder section lM Dated 3A.03.2024 vide DIN No ITBA/ASTlSll 4i3_112023- 241fi63686905(1[or the Assessment Year 2O2O-21 and the consequential order passed bythe {st respondent u/s. 147 r.w.s 144of the lncome-tar: Act Date of Order 29,fl5.2025, DIN ITBA/AST|S|147|2O25- 26t1O7656O262(1) for ttre Assessment Year 2O2O-21, as arbitrary, illegal, bad in law, void ab ini, tio, violation of principtes-of na.tural justice apart from violation of Articles 14, 19 tf Xg) and 265 of cor, stitution of lndia apart from being violative of provisions of section 148 A and sectiort 149 of the Act and also contrary to the circular issued by CBDT and provisions of section 1514 of the Act, and consequentty set aside the order passed by'1st l?espondent u/s. 147 r'.w.s 144 of the lncome-tax Act Date of Order 2glOSl2O25, DIN ITBA/AST lst147t2A25- 2611076ffiO262(1)for the Assessment Yebr 2020- 21 and all consequential proceedings purcuant there to. lA NO: 1 OF 20116 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 theorder passed by the Respon, Cent u/s. 147 r.w.s 144 of the lncome-tax Act Date of Order 73 nlOSl2O2S, DIN: ITBA/AST/SI1 47 12025-Xi11O76560262(1) for the Assessment Year 2O2O- 21and stay of Demand notice under section 156 Dated 2gtOSt2O25 vide DIN No ITBA/AST/S/1 56t2O25-26/1076560288(1) for the Assessment Year 2O2g-21, pending disposal of the writ petit'ron. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent No.{ & 2: SRI P.VIJHAY K.PUNNA" Sr. SC FOR lT Counsel for the Respondent No.3: SRI N.BHUJANGA RAO, DEPUW SOLICITOR GENERIAL OF INDTA Between: Medikonda Bhavani, Wo. Occupation Hornemaker, R/o Kapra Rangareddy 500051 Assessment Year 2015-16 Medikonda Prasad Plot No 74 Ec Nagar Telangana, about 44 years, Post, Hcl 10M, PAN: .".PETITIONER AND 1 Assessment Unit, National Faceless Assessment Department, Ministry of Finance, Room No. 4O1, Jawaharlal Nehru Stadium, Delhi 110 003. Centre, lncome Tax 2nd Floor, E-Ramp,

#2. The lncome Tax Officer, Wardl 5(1), Masab Tank, Hyderabad, T I T TOWER, AC Guards,

#3. Union of lndia, Represent by Secretary Ministry of Finance North Block, New Delhi-l10 001 ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of WRIT OF MANDAMUS holding that the notice issued (JAO) by 2nd Respondent under section 148 Dated' 07.04.2022 vide DIN No ITBA/AST/51148_112022- 2311042596639(1[or the Assessment Year 2015- 16and the consequential order passed by the 1st respondent u/s. 147 r.w.s 144 read with section 144Bof'the lncome-tax Act Date of Order 15.02.2024, DIN ITBA/AST/51147 12023-2411060939855(1 )for the Assessment Year 2015-16, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice 74 apart fmm violation of Articles 14,19 (1[g) and 265 of constitution of lndia apart- from being violative of provisions of seetion,t4SA and section 149 of the Act and also contrary't,r the circular issu6d by CBDT and provisions of section 151A of the Act, and consequently set aside the order passed by 'tst Respondent u/s. 147 r.w.s 144 read with section 144Bof the lncome-tax Act S Date of Order 1 5M2.2O24, DtN: ITBA/AST l9t'l 47 12023-24/1 060939855(1 fior the Assessment Year 2O15- 16 and all consequential proceedings.pursuant thereto. lA NO: 1 OF 2026 Petition ,under Sectioh 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 theorder passed by the 1St Respondent uls. 14V r.w.s 144 read with section '144tJ ot the lncome- tax Act Date of Order 15.A2.2024, DIN: }TaA/AST/S/14712023-2411060939855(1) for the Assessment Year 2015-16for the Assessment Year 2015-16 and stay of Demand notice under sectlon 156 Dated: 15.02.2024 vide DIN No : ITBA/LST/S 1 1 56 1202? 2411 0O0939893( 1 ) fo r the Assessme nt Yea r 201 5- 1 6, pending dispos'al of the vyrit petition. Counsel fortheFetitioner: SRI THANNERU CIIAITANYA KUMAR Counsel for ther Respondent No.I & 2: SRI VIJHAY PUNNA .K Sr. SG FOR lT Counsel for the Respondent No.3: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERAL OF INDIA a o l Between: Tricolour Properties Private l-imited, A Private Limited Company incorporated under Companies Ac{, 1956 D.No.6-3-25'll4,Balapura, Road no. 1, Banjara Hills, behind GVK mall, Khairatabad, Hyderabad, Telangana- 500034 Represented by its Authorized Signatory Mr. B. Madhav ...PETITIONER AND \ 75

#1. Assistant Comrnissioner of lncome Bhavan, Opp. LB Stadium Aayakar 5m004

#2. Central Board of Direc{ Taxes Central Block, New Delhi - 1l000l Centre

#3. Commissioner ff lncome Tax. (Aooeals). lT Towers, 10-2-3, AC Guards, Hyttbrab#, Central Circle 1 3( ), Hyderabad Telangana - Secret, Central Secreta riat, North by National Faceless Assessment 11 Sth Floor, D-Block, 500004 Petition under Article 226 of the Constitution Of lndia praying that in the circumstances stated in the affrdavit filed the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the. (a) Digitally Signed Notice u/s. 148 of the Act vide DtN & Notice No. ITBA/AST/S/148_112022-2311059159656(1) dated 28.12.2023 issued by Respondent No. 1 in Exhibit P1, (b) Digitally signed Assessment Order uls. 147 of the Act bearing DIN and , Order No. ITBA/AST/S/1 4712023-241'1063797857(1) dated 31.03.2024 passed by Respondent No. 1 in Exhibit P2, and (c) Digitally signed Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBtuAPL/S/2S0 12025-26,,1082884139 (1) dated 21-11-25 passed by Respondent No. 3 in Exhibit P3. and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. Petition under Section '15'l CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation of and all recovery and penal proceedings in pursuance of the Digitally Signed Notice u/s. '148 of the Act vide DIN and Notice No. ITBA/AST/S/148_112022-2311059159656(1) dated 28]12.2023 issued by 76 Respondent No. 1 inExhibit P1; Digitally signed Assessmenl Order uls. 147 of the Act bearing DIN and order No. ; ITBA/AST/SI 14Vt2O23-241 1063797857 (1) dated 31 .03.2024 passed by Respondent No. 1 in Exhibit P2 and pass Digitally signed Appellerte Order u/s 250 of the Act bearing DtN and Order No. ITBAIAPUS/25A2O25;26L11O82884139(1) dated 21.11.2025 passed by Respondent No. 3 in Exhibit P3 and pass any such other order or orders, as the Honble Court may deem fit and proper in the circumstances of the case, as the of the lmpugnrsd Assessment Order and lmpugned Appellate Order, both of which suffer fr<rm various legal and factual infirmities, would suffer irreparable trardsnip if coerclve recovery is continued, whereas no prejudice will be caused: to the Slevenue if recovery is stayed during the pendency of this Writ Petition.. Counsel forthe Petitioner: SRI SANTOSH SAG forthe'Respondents: SRI N.PRAVEEN REDDY, Sr. SC FOR !T 0 e .i! 1 I Tricolour -uiidEr Hills, Represented Private Limited, A Private Limited Company , Road'iio. f, Telangana- AND l. Assistant Aayakar s00004 rBhdvan, Opp. l-B Stadium Basheerbagh of lncome Tax Central Circle - 3(1 , Hyderabad ),

#2. Central Board of Direci Taxes, Central Secretariat, North Block, Neur Delhi - 110001 Represented by National Faceless Assessment Centre

#3. Commissrioner Of lncome Tax lT Tourersr, 10-2-3, AC Guards, (Appeals), Hyderabad 11 Sth Floor, D-Block, -500004. FFFIItrNIITIIIS Petition under Article 226 ot lhe Constitution of lndia praying that in the in the affidavit filed therewith, the High Cou( may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set circumstances stat€d aside the \ 77 (a) Digitally Signed Notice u/s. 148 of the Act vide DIN f, ITBA/AST/S/148J12o2Y2411056734751(1) dated o3l1ol2o23 Respondent No. 1 in Exhibit Pl Notice No issued by (b) Digitally s[ned Assessment Order uls. 147 of the Act bearing DIN and Order No. IT84/A5T/5114712023-2411063735062 (1) dated 31.03.2024 passed by Respondent No. 1 in Exhibit P2 and (c) Digitally signed Appelfate'order u/s 250 of the Act bearing DIN and Order No. |TBA/APUS/25O1ZO2S26!1O82894544(1) dated 21.',t1.2O2s passed by Respondent-No. 3 in Exhibit P3, and all other consequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and. violative of the. provisions of the lncome-tax Act, 1961 and Articles 14 and 19(1[9) of the Constitution of lndia. lA tlo: 2 OF 2026 Petition under Section 151 CPC praying that in the circurnstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation ofand all recovery and penal proceedings in pursuance of the Digitally Signed Notice u/s. 148 of the Act vide DIN & i,lotice No ITBA/AST 12023-241 10567 34751 (1 ) dated O3l 1 Ol2O23 issued by Respondent No. 1 Sl 1 48 in Exhibit Pl Digitally signed Assessment Order uls. 147 of the Act bearing DIN & Order No. ITBA/AST/S/'!4V|2O23-2411063735062 (1) dated 3110312024 passed -1 by Respondent No. 1 in Exhibit P2 and pass Digitally signed Appellate Order u/s 25O ot the Act bearing DIN and Order No. ITBtuAPUS/25O12025-261 1082894544(1) dated 2'U11nO25 irassed by Respondent No. 3 in Exhibit P3 and pass any such other order or orders as the Honble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its retumed income as a result of the lmpugned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer irreparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. 78 Counse] for thi: Petitioner: SRI SANTOSH SAGAR KAPILAVAI I eouniel forih: neiponoents: sRl N.PRAvEEU nEoDv, sr. Sc Fon m Behreen.: Tficolour Properties Private Limited, A Private Limited Company incorporated under Crmpanies, Act, 1956 D.No.6-3-25114, Balapura, Road no. 1, Banlar:a Hills, be, hind GVK mall, Khairatabad, Hyderabad, Telangana- 500034 Represented by its Authorized Signatory Mr.8. Madhav trTlril

#1. Assistant Commissioner of lncome Tax, Centr:al Circle - 3(1),'Hyderabad {qyal6ar Bhavan, Opp. LB Stadium Basheerbagh, Hyderabad, Telbngana - 500004

#2. Central Eloard of Direct Taxes, Central Secretariat, North Bloclq New Delhi - 11000i Ftepresented by National Faceless Assessment Centre

#3. Cqrnmiss'ioner Of lncome Tax (Appeals), Hyderabad- 11 sth Floor, D-Bl'ock, lT Towens, lO-2-3, AC Guards, Hyderabad, Telangana 500004 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to-issu,e Writ of Certiorari or any other appropriate writ, or direction to set aside ttte .RESPONT}ENTS (alDigitafly Signed Notice u/s. 148 of the Act vide DIN and Notice No ITBA/ASilS/148-1 12O22-23t1O59159650(1 ) dated 28.12.2023 isured by Respondent No.1 in Exhibit P1 (b)Digitally signed Assessment Order uls. 147 of the Act bearing ,DlN 86 'Order No. ITBA/ASTlSt147t2O23-24t1O63797679(1) dated 31.O3.2O24 passed by Respondent No. 1 in Exhibit P2 and (c) Digitatly t;igned Appellate Order u/s 250 of the Act bearing DIN and Order No. ITBA/APL/S/25012025-26/1 082885981 ( 1 ) dated 21 -1 1 -2A21 passed by Respondr:nt No. 3 in Exhibit P3. and all other consequential actions, penal and recovery .proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the \ 79 lncome-tax Act, 1961 and Articles 14 and 19(txg) of the Constitutinn of lndia. TA NO: 1AF2p,26. 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 the operation of and all recovery and penal proceedings in pursuance of the Digitally Signed Notice u/s; 148 of the Act vide DIN & Notice No: ITBA/AST/S/ 148..1t2O22:2311059159650(1) dated 28.12.2023 issued by Respondent No. 1 in Exhibit Pl: Di,gitally signed Assessment Order uls. 141 of bearing DIN & Order No. ITBA/AST/S/14712O23-24116379767q1) dared 31.03.2O21 gassed by Respondent No. 1 in Exhibit P2 and pass Digitally signed Appellate Order u/s 25O of the Act bearing DIN and Order No ITBA/APL/S/2SO|2O2S- 2611082885981(l)dated 21111125 passed by Respondent No 3 in Exhibit p3 and pass any such other order or orders as the Honble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its retumed income as a result o the lmpugned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmities, would suffer irreparable hardship if coercive recovery is continued, whereas no preiudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Gounsel for the Petitioner: SRI SANTOSH SAGAR KAPILAVAI Counsel forthe Respondents: SRI N.PRAVEEN REDDY, Sr. SC FOR tT 0 I Between: p1fply Agricultural Cooperative Credit Society Limited, Lingampet, FUo. lVs lacs Ltd Lingampet, Mllage Post, Lingampet Mahdal, Nizamabad'503123, Telangana. Bep Qy. Pulgala Pentaiah, S/o. Mr. Pulgala Durgaiah, aged 56years, Occ.. -Cooperative Secretary anlC Chief-Executive Officer of Primafo Agriclltural Credil Sbciety Limited !.ingampet, R/o. H.No.3-93, nimaii poor, Yeitareddy Mandalam, Jangamaipalle, Nizamabad, Telangana - 503122 ...PETITIONER 80 AND 1, Asse-ssrenl U-nit, lnome Tax Departqteqt, Nalisoal 9.-A.sgesslngllt Center, - .Netr tAlhi;-fioom ruo.aot, 2nd Floor, E:Rarnp, Javaharlal Nehru Stadium, Neur Dellri - 110 O03.

#2. The lncc, me Tax Officer Ward 1, Nizambad, lncome Tax Office, 6'2'156t3, Subhash Nagar, N2amabad, Telangana, 503002

#3. The Prirrcipal Commissioner of tncome Tax - 2,.Hydem-bacl, lncome Tax Towers, ,AC Guards, Masab Tank, Hyderabad - 500 004, Telangana.

#4. The Joint Commissioner (Appeals) / the Commissioner of lncome Tax (Appeats), National Faceless Appeal Centre, Delhi, Thrcugh the Principal Ctii6f Coihmissioner of lncome Tax, (NaFAC), Delhi, North Block, New Delhi - 1r0 001.

#5. The Central Board of Direct Taxe of Revenue, Ministry of Finance, ,New Dethi - 1 10 001 . s, Represented by its Ghairman, Department Govemment of lndia, Secretariat Buildings, ...RESPONT}ENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the aflidavit filed therewith, the High Gourt may be .pleased to issr.Ie a Writ of fulandamus or any other appropriate Writ, Order or Direction, declaring that the a. the Order pa, ssed by the 1 st Respondent, uls 147 .r/w Sec. 1448 of the lncome Tax ACt, 1961, dated 26.05.2023, bear, ing DlN.. FAAfASYtSl147l2O23' 24.11053230520(1), for the Assessment Year 2016 - 17, as corifinned by the order of the 4th Respondent dated 21.12.2O23, vrde DIN and Order No.ITBANFAClSl25Ol2O23-241 1058974075(1), passed u/s 250 of the lncome TaxAct, 1961, b. consequential penalty order passed by the 1st Respondent, levying penalty u/s 271(1Xb)o[ the lncome Tax Act, 1961, dated 27.03.2024, bearing DlN. ITBA/PNUF/27 1 (11(by2o23-24l1 063468306(1 ), for the Assessment Year 201 6- 17, c. coRsequential penalty order passed by the 1st Respondent, levying penally u/s 271F ot lhe lncome Tax Act, 1961, dated 30O3.2025, rbearing DlN. ITBA/PNUF/271F12O24-251 1075289337(1), for the Assessment Yeat 2016 - 17. .\-l 8l as arbitrary, illegal, barred by limitation, bad in law, void-ab-initio, violative of the ,principles of naturatjustice, apart from being violative sf Articles 14, lg(1xg) and 265 of the Gonstitution of lndia & Sec 148A of the lncome Tax Act, 1961, and to consequently set asirJe the same in the interests of justice. lA NO: 1 OF 2026 , . Petition under Section 151 CPC praying that in the circumstanoes stated in the affidavit filed in support of the petition, the High Court may be pleased to stay all further progeedings; inctuding any recovery, pursuant to, the notice .u/s 148 of the lncorne.tax Act, 1961, dated 22.07.2022, issued by the 2ndRespondent, for the Assessment Year 2016-17, pending disposa! of the above Writ Petition. Counsel for.the Fetitioner: Ms. SYEDA SAJIDA SAMAREEN FATII[IA Counsel for the Respondents: Ms. J.SUNITHA, Sr. SC FOR lT Between: Tricolour Properties Private Limited, A Private Limited Company incorpomted g-$er Comp.anies Act, 1956 D.No.6-3-25114, Balapura, Road no. 1, Banjara Hills behind GVK mall, Khairatabad, Hyderabad, Telangana- 500034 Represented by its Etirector Mr. Chandan Kumar Jha ...PETIT]ONER AND

#1. Assistant Comrnissioner of lncome Tax, Central Circle - 3(1) Aayakar Bhavan, Basheerbagh, Hyderabad, Telangana - 500004

#2. 'National Faceless Assessment Centr.e, Room No. 402, 4th Floor, Mayur Bharrran,.Connaught Lane Connaught Place, New Delhi - 110001

#3. Cornmiss'roner Of lncome Tax (Appeals), Hyderabad- 11 sth Ftoor, DBlock, lT Towers, lA-2-3, AC Guards, Hyd-erabid, Telangana 500004

#4. Central Board of .Direct Taxes, Rep by Secretary, Central Secretariat, North Block,.New Delhi - 110001

#5. Union of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi - 110001

#6. {oin! Commissioner of lncome Tax, Central Range - 3 Aayakar Bhavan, tsasheerbagh, Hyderabad, Telangana - 500004 ...RESPONDENTS E2 Petition under Arlicle 226 of lhe Constitution of lndia praying that.in the the affidavit filed"therewith;-'the'High Gourt may-be '€irctrmstances.slated'.in pleased to issur] Writ of Certiorari or any other appropriate writ or direotion to set aside the. (a) Digitally Signed Show Cause Notice u/s. 274 r.w.s. 271D4 beaing DIN and Notice No. ITBA/PNUS/271DN2O24-25I1O70830216(1) dated 03.12.2024 passed by Respondent No. 6 in Exhibit F2. (b) Digitally Signed Penalty Order u/ s. ITBA/PNL/F/2 7't D N 2025-26 I 1 07 7 1 5254\1) 2V1DA of the Act bearing DIN dated 18.06.2025 passed by Respondeht No. 1 in Exhibit P3. (c) Digitally Signed Ex-parte Appeal Order u/s. 250 beadng DIN and Order No. ITBA/APL/S/25012025-26fi083032712(ll dated 26.11.2025 passed by Respondent No. 1 in Exhibit P4. and all other c()nsequential actions, penal and recovery proceedings for being illegal, arbitrary, unlawful and violative of the provisions of the lncome-tax Act, 1961 and Articles f 4 and 19(1 Xg) of the Constitgtion of lndia. lA NO: 1 OF 201r-6 Petition trnder Section 151 CPC praying that in the circumstances stated in the affidavit liled in support of the petition, the High Court may be pleased to stay the operaticn of and all recovery and penal proceedhgs in pursuance of the Digitally Signecl Show Cause Notice u/s. 274 r.w.s. 271DA bearing DIN and , Notice No. lIBA/PNL/S/271DN2024-25/1070830216(1) daled 03.12.2024 passed by Respondent No. 6 in Exhibit P2, the Digitally Signed Penalty Order uls.27'lDA of the Act bearing DtN ITBA/PNLlFl271DN2O25-261 1077152547(1') dated 18.06.20:25 passed by Respondent No. 1 in Exhibit P3 and the Digitatly Signed Ex-parte Appeal Order u/s. 25O bearing DIN and Order No. ITBA/APL/S/25(V2O25-2611O83032712(1) dared 26.11.2025 passed by Respondent No. 1 in Exhibit P4 and pass any suoh other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its retumed income as a result \ 83 of the lmpugned Assessment Order and lmpugned Appellate Order, both of which suffer from various legal and factual infirmitles, woutd suffer ir, reparable hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition: Counsel for the Petitioner: SRI SANTOSH SAGAR KAPII-AVAI Counsel for; tfie Respondent No.l to 4 & 6: SRI N.PRAVEEN REtrDY, Sr. SC FOR lT Counsel for the Respondent No.S: SRI N.BHUJANGA RAO, , ...,' ,t, , '' .: ' ,. , DEPUW SOLICITOR GEN_ERI,AL OF IND|A Between: thubhanandini lnfrastructures, R-ep by Managing Parrner, Koudagani Ram ba bu, #3-34 I 1 lB, B ru nd havan i Colo ny, Ha namkorida, Telargana-50600 1 . AND ...PEflTTONER

#1. The lncome Tax Officer, Ward - 1 Warangal, lncome Tax Office, D No. 1-8- q-10, 3{d FIooq, Mayuri Complex, OPP. TSNPDCL Bhawan, Nakkalagufta, Hanamkonda, Warangal, Telangana-50600 1 .

#2. Jhe Principal Commissioner of lncome Tax-1, Hyderabad, il.T. Towers,A.C. Guards, Hyderabad, Telangana-500004.

#3. The Assessment Unit, tncome Tax Department, I.lational Faceless Assessnrent Centre, Delhi, Ministry of Finance, Roorn No. 4O1 ,2nd Floor, E- Ramp, Jawaharlal Nehru Stadium, Delhi-l10003. ...RESPONDENTS Petition under Arthle 226 of the Constitution of lndia praying that in the circumstanc.es stated in the affidavit filed therewith, the _High Court may be pleased to issue an appropriate writ order or direction more particularly one in the natune of Writ of Mandamus, declaring the Assessment Order dt. 16.05.2023 passed by the 3rd respondent uls 147 r.w.s 14411448 of the lncome-tax Act for A.Y. 2017-18 vide DIN No. ITBA/AST lst147t2}23-2411052851816(1), consequent to the order passed u/s 148A(d) dt. 29.07.2022 vide DIN No. ITBA/COMlFltll2O22-2311O44258245(1) and the notice u/s 148 dt. 29.07.2022 vide DIN No. ITBA/AST/M/1 48_112022-2311044339100(1 )issued by the JAO(1st respondent) instead of FAO(3rd respondentlthat too based on the incorrect E4 information, and consequential per, ral{y order passed vide order u/s 2724(1 Xd) of the *ct dt,25;l0.2023as void; illegal; and contraryto-the provisions of lncome- tax Act and corilrary to the Principles of Natural Jras*ice. fANO: I oFm2s, Petition ,.rnder Section 151 CPC praying that in the circumstances stated in the affidavit fited in support of the petition, the High Court may be pleased to pursuant to the Assessment Order dt. stay all further 16.05.2023passed by the 3rdrespondent uls 147 t.w.s 14411448 of the lncome- tax Act for A.Y. 2017-18 vide DIN No. ITBA/AST/S,114712O23-2411052881816(1) and the Penaltf orders, and may pass such other orde(s) as the Hon'ble Court deems fit arid proper in the interests of substantial justice, as otherwise the Petitioner woukl be put to ineparable loss and severe iniury. Counsel forthe Petitioner: SRI DUNDU SASHANK, REP SRTUINIIUTffTTrqINN Counsel for ther Respondents:,Ms. BOKARO SAPNA REDDY, Sr. SC FOR IT 3 :l o :l BDECCS Limited, Regd Rep., by its Secretary, Sri P. Murali No.TA 8Ol S/o. , R.R. District -500008. P. Nageswara Rao D 1 Assessnx?nt Unit, National Faceless Assessment Centre, lncome Tax Department, Ministry of Finane, Room No. 4O1, 2nd Floor, E-Ramp, Jawaharlal Nehru Stadiurn, Delhi -1tO 0D3.

#2. The lncome Tax Officer, Ward - 9(1), l.T. Towers, A.C. Guards, Masabtank, Hyderabad - 500004. .PETITIONER ...RESPONDENTS Petition under Article 226 ot the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to pas:; an order or direction, especially one in the nature of WRIT OF MANDAMUS holding that the notice dated 31.03.2025 issued by 2nd Respondent under section 148 of the Act with DIN and NOTICE \ 85 No.ITBA/AST/S1148_1nA24-2511075347161(1) as being without jurisdiction, arbitrary, illegal, bad in law, void ab initio, apart from being violative of provisions of section 1514 of the Act and also contrary to the circular issued by CBDT, and consequently set aside the notice under section 148 dated 31.03.2025, the assessment order passed by 1st Respondent for asst. year 2O21-22 under section 147 r.w.s 1448 of the Act, dt.05.12.2o25. Petition under Section 151 CPC praying that in the circumstances stated in the afiidavit filed in support of the petition, the High Court rnay be pleased to stay all further proceedings including collection of tax demand raised by the 1st Respondent for the Ay.2O21-22, pending disposal of the writ petition. Counsel for the Petitioner: SRI A.V.RAGHU RAM Counsel for the Respondents: SR! K.SUDHAKAR Sr. SC FOR lT o c o I Represented by its Director Mr. Chandan Jha Limited . no. 1, , Telangana- =t D 1. Assistant Cornmissioner of lncome Tax, Central Circle - 3(1) Aayakar Bhavan, Basheerbagh, Hyderabad, Telangana - 500004

#2. National Faceless Assessment Centre, Room No 2t02, Bhawan, Connaught Lane Connaught Place, New Delhi - 1't 4th Floor, Mayur l'l

#3. Commissioner Of lncome Tax lT Towers, 10-2-3, AC Guards, (Appeals), Hyderabad- 11 Sth Floor, D-Block, Hyderabad, Telangana 500004

#4. Central Board of Direct Taxes Rep by Secretary, Central Secretariat, North Block, New Delhi - 110001

#5. Union of lndia, Rep by Secretary, Ministry of Finance, North Block, New Delhi - 110001

#6. Joint Commissioner of lncome Tax, Central Range - 3 Aayakar Bhavan, Basheerbagh, Hyderabad, Telangana - 500004 86 ...RESPONDENTS - Petilion rlnder Article 26-of tlte-Constitution of ]ndia prayins that in the circumstances stated in the affidavit fiied ttrerewith, the High Court may be pleased lo issue Writ of Certiorari or any other appropriate writ or direction to set aside the (a) Digitally Si€lned Show Cause Notice uls.2l4 r.w.s. 271DA bearing DIN and ---Notiee-. No- f]:BAIPNLIS/221DN2A24.25,L_IO7jE,30416(a) - dated--03. 1 2. passed by RespondentNo. 6 in ExhibitP2. (b) Digitally S(7ned Penalty Order u/s. 271DA of the Act bearing DIN ITBA/PNL/F/271ON2025-261 10771A7455(1) dated't8.06.2025 passed by Respondent No. 1 in Exhibit P3. (c) Digitally Signed Ex-parte Appeal Order u/s. .250 bearing DIN and Order No. ITBA/APL/S l250l 2025-s,1 1083035296(1) dated 26.11.2025 passed by Respondent No. 'l in Exhibit P4. and all other consequential actions, penal anil recovery proceedings for being illegal, arbitrary', unlawful-and violative.of (he provisions of the lncorne-tax Act 1961 and Artick:s 14 and 19('l)(g)of the Constitution of lndia. !A NO: 1 OF 20:m Petition under Section 't5'l CPC praying that in the circumstances stated in the affidavit liled in support of the petition, the High Court may be pleased to stay the operation of and all ,recovery and penal proceedings in pursuance of the Digitally Signed Show Cause Notice uls. 274 r.w.s. 271DA bearing DIN and Notice No. ITBA/PNUS/271DN2O24-25I107083M16(1) dated 03.12.2024 passed by Respondent No. 6 in Exhibit P2, the Digitally Signed Penalty Order u/s. 271DA of the Act bearing DIN ITBA/PNUF|271DN2O25-261 1077187459(1) dated 18.06.20:25 passed by Respondent No. 't in Exhibit P3 and the Digitally Signed Ex-parte Appeal Order u/s. 25O bearing DIN and Order No. ITBA/APL/S/25012025-2611O83035296(1) dated 26.11.2025 passed by Respondent No. 1 in Exhibit P4 and pass any such other order or orders as the Hon'ble Court may deem fit and proper in the circumstances of the case, as the I 87 Petitioner, being fastened with huge additions to its retumed ineome as a result of the lmpugned Assessment Order and lrnpugned Appellate Order, both of which suffer ft'om various legal and factual infirmities, would suffer irreparabte hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel for the Petitioner: SRI SANTOSFI SAGAR I(APILAVAI Gounsel for the Respondent No.1 to 4 s, o: :T;1S| ir=N :...---- REDDY, ,;. Counset for the Respondent No.5: SRI N.BHUJANGA RAO, DEPUW.SOLIC]TOR GENERIAL OF INDIA Between: Giridhara Rama Kumar, S/o late Ch.V. Satyanarayana Murthy Aged yga.rs Ocg Business R/o 2O3 and 91162 Ralhavendra Hyderabad Hyderabad 500047, Telangana lndia -Apis about 51 Malkajgiri AND

#1. Assessment Unit, lncome Tax Department, National e-Assessment Center, Rogm, No.401 , 2nd Floor, F-Ramp, Jawaharlal Nehru Stadium, New Delhi- 1 10 003. ...PETITIONER

#2. lncome Tax fficer, ward12(1)Hyderabad Pclr-l,Aayakar Bhavan, Hyderabad-500004

#3. Commissioner of tncome tax (Appeals), Nationat Faceless Appeal Centre (NFAC), C-Block, 4th. Floor, S P.M Civic Centre, New Delhi - 110001.

#4. Principal Chief Commissioner of lncome T-ax, Andhra Pradesh and Telangana, Hyderabad 10-2-3, Room No.922, 9th Floor, B Bbck, lT Towers, AC Guards, Hyderabad-SOO 004

#5. Union of lndia, Rep. by its Secretary, Ministry of Finance, Govemment of lndia, 3rd Floor, Jeevan Deep Buitding, Sansad New Delhi-110 001 -Marg, Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a Writ of Mandamus or any other appropriate writ, order or direction ...RESPONDENTS 88 (a) declaring the notice under Notice under Section 148 of the lncome Tax Act, 196-1,-dated Z{:tlOltzOZ+ passed by 2nd .Flespondent for the'assessmentJear 2O2O-21as being without jurisdiction and contrary to faceless assessmerlt procedure laid down in Section 144Bot the lncome Tax Act 1961and consequently. the stbsequenl proceedings in order under Section 147 dated (b) to set-asld€ 3olo1l2125 issrred by the tst Respondent and proceedings under Section 250 dated 23l1Ol2O:25 issued by the 3rd Respondent for the assessment year 2( t20- 21 as being without JuJisdiclion, arbitrary, illegal, bad in law, void-ab-initio, apart from being viol, ative sf Articles 14,19('1[9) and 265 of the Constitution of lndia and contrary to faceless assessment procedure laid down in Section 1448 of the lncome Tax Act 1961 and oonsequently set-aside the same in the interests of justice. lA NO: 1 OFmfr Petition'under Seotion 151 CPC praying that in the circumstances stated in the affidavit f iled in sqpport of the petition, the High Court may be pleasefl to grant siay oi aLI.-fUrth.eL,pJgc-99{ings, including any recovery, pursuant to the- impugned notir:e under Seotion 148 dated 28.03.2024 issued by the 2nd Respondent, urrder Section 147 read with Sections 144 &1448 of the lncome Tax Act, 1961for tf€ assessment year 2O2O-2'l subsequent proceedings in order under Section 147 dated 30.01.2025 issued by the 2nd Respondent and order under Section 250 dated 23-10.2025, pending disposal of the Writ Petition as otherwise the Petitioner will be put to severe loss and hardship. Counsel forthc, Petitiorier: Mg AKRUTI AGARWAL Counsel forthe, RespondentNo.l to 4: Ms. BOKARO SAPNA REDDY, Sr. SC FOR lT Counsel for the Respondent No.5: SRI N.BHUJANGA RAO, DEPUW SOLICITOR GENERIAL OF INDIA \ Between: 89 Tricolour Properties Private under Companies Act, 1956 Hills, behind GVK mall, Represented by its Director Mr. Chandan A Private Limited Jha Company incorporate Road no. 1, Banjara Telangana- 500034 ...PETITIONER NND

#1. Assistant Commissioner Gentral Circle - 3(1) Aayakar Bhavan,

#2. Room No 402, 4th Floor, Mayur New Delhi - 11m01

#3. Commissioner Of tncome Tax lT Towers, lO-2-3, AC Guards, (Appeals), Hyderabad- 11 sth Floor, D-Block, Hyderabad, Telangana 500004

#4. Central Board of Direct Taxes, Rep by Secretary, Central Secretariat, North Block, New Delhi - 110001

#5. ury-oryof lndia, Rep by secretary, Ministry of Finance, North Btock, New Derhi - 1 10001

#6. Joint commissioner of lncome Tax, Central Range - 3 Aayakar Bhavan, Basheerbagh, Hyderaba( Telangana - 500004 ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue Writ of Certiorari or any other appropriate writ or direction to set aside the (a)Digitally Signed Show Cause Notice uls. 274 r.w.s. 271DA bearing DIN and Notice No. ITBA/PNLlsl271DN2O24-2511O7O829646(1) dated 03.12.2024 passed by Respondent No. 6 in Exhibit P2. (b)Digitally Signed Penalty Order ul s. 271DA of the Act bearing DtN ITBA/PNLIF|271DA|2025-261 1077150296(1) dated 19.oo.2a2s passed by Respondent No. 1 in Exhibit P3. (c) Digitally Signed Ex-parte Appeal Order u/s. 250 bearing DIN and OrderNo. ITBA/APLlsl25ol2o25-2il1a83031416(1) dated 26.11.2o2s passed by Respondent No. 1 in Exhibit P4. 90 and all other consequential actions, penal and recovery proceedings for being illegat; arbitrarl', unlawful and.violative of.the .provisions of the lncome-tax Acti 1961 and Articles 14 and 19(1Xg) of the Constitution of lndia. Petition urider 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 the gpgrratiion of and all recorrery and penal proceedings in pursuance of the Digitalty Signed Show Cause Notice u/s. 274 r.w.s.271DA bearing DIN and Notice No. ITAAIPNL/SI2V1DN2O24-25I1070829646(1) dated 03.12.2024 passed by Respondent No. 6 in Exhibit P2, the Digitally Signed Penalty Order u/s. 271DAof lhe Act bearing DIN: ITBA/PNL|F|271ON2O25-261 1077150296(1) dated 18:06.2025 passed by Respondent No. 1 in Exhibit P3 and the Digitally Signed Ex-parte Appeal Order u/s. 250 bearing DIN and Order No. ITBA/APUS/2 5012025-26 I 1 083031 4 1 6( 1 ) 26. 1 1 .2025 passed by Respondent No. 1 in Exhibit F4 and pass any such other order or orders as the Hon'ble .Court may deem fit and proper in the circumstances of the case, as the Petitioner, being fastened with huge additions to its returned income as a result of the impugred' -Assp.ssment Order and lmpugned Appellate Ordeq.toth-of-thich suffer from..various legal and factual infirmities, would suffer irreparable'hardship if coercive recovery is continued, whereas no prejudice will be caused to the Revenue if recovery is stayed during the pendency of this Writ Petition. Counsel for tfie Petitioner: SRI SANTOSH Counsel for the, Respondent No.'t to 4 & 6: N.PRAVEEN REDDY, Sr. SG FOR tT Counsel forlhe Respondent No.S: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERIAL OF INDA o 50 {rl ) AND 9l

#1. Nationd Faceless Assessment Centre,, Delhi, Ministry of No.401, 2nd Floor, E-Ramp, Jarnraharlal irlehru Stadium, itevtr Finance, Room Delhi-110(x)3.

#2. The Asst. Commissionerof lnoome Tax, Circle-l2(1). Hvderabad. lncome Tax 9flqg-,-Agykar Bhawan, Opposite LB Stadium, B'asheer Bagh, Hyderabad - 500004, Telangana ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may tie pleased to issue a writ, qr-de1 or direction; more particularly one in the nature of Writ of Mandamui, dectaring the notice u/s 148 dated 04.04.2O22 vide DIN No. ITBA/AST/S/r48-112O22-2311042487}32(1) issued by the JAO (Respondent No.2) instead of Respondent No.1(FAO) for A.Y.2018-19 as void;. illegal and contrary to the provisions of lncome-tax Act and contrary to the Constitutional Provisions including Principles of Natural Justice. lA NO: 1 OF m26 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the l-ligh Court may be pleaserJ to stay all further proceedings pursuant to the notice u/s 148 dated O4.O4.2O22 vide DIN No. ITBA/AST/S/148_112022-2311042487932(1) issued by the JAO (Respondent No.2) instead of Faceless Assessing Officer (FAO) for A y.2018-19. pending disposal of the su$ect writ petition. Counsel forthe Petitioner: llr.$rudhvi raj LEARED COUNSEL RESPRESTING SRI T.V.L.NARASIMHA RAO Counsel for the Respondents: Ms. B.SAPNA REDDY, Sr. SC FOR lT 3 0 a t :l Between: Jawahamagar Educational Society, Rep. by Principal Kasula Venkata Narasimha Reddy S/o. Dharma Reddy Kaiula Agbd about 55 years, Occupation Busin6ss, FUo. Jawahamagaf Pinion High-School, Jawahamagai Balajinagar J.J.Naga'r Colony Yaprai Kapra Med-chat Mati<ajgiri 500067, Telangana, lndia PAN.AACAJ8493R, Assessment Year. 201 8-1 I ...PETITIONER 92 AND . - 7.- Assessmerit Unt,-National Faceless Ascessmen!,C-q-1!!8, lnom-e--T,ax_ 'Department, Ministry of Finance, Room No. 4O1, 2nd Floor, E-Rarnp, Jawaharl, al Nehru Stadium, Delhi -110 003. 2- The lnccrne Tax Officer, Ward 15(1), Hyderabad lT Tower, AC Guards, Masab Trrnk HyderabaG50@04 Telangana

#3. Union of lndia, Represent by Secretary Ministry of Finance l.lorth Block, New Delhi-l1(l 001 ...RESFONDENTA Peiition rrnder Article 226 ot lhe Constitution of lndia prayrns tiiat iri the circumstances stated in the affidavit filed therewith, the High ,Count may be pleased to issue an appropriate writ, order or direction more particularly one in :, lhe nature of WRIT OF MANDAMUS holding that the notice issued (JAO) by 2nd Respondent under section 148 Dated. 23.04.2022 vide DIN No. ITBA/AST/S/1 48_112022-23110'42830012(1 )for the Assessment Year 2018-19ard the conseguential order passed by the 1st respondent uls. 147 read with section 144Bsf the lncome-tax Act Date of Order 12fi3.2024, DlN. ITBA/AST/S/1 47 12023-241 I 062426264(1 )tor the Assessment Year 201 8-1 9, as arbitrary, illegal, bad in law, void ab initio, violation of principles of natural justice ap_?n frcm vio-la:tion of Articles 1 4, 1 I ( 1 Xg) and 265 of constitution o-f tndlq ap_a[ frorn being violative of provisions of section 148 A and section '149 of the Act and also iontrary to the circular issued by CBDT and provisions of section 151A of the Act, and crrnsequently set aside the order passed by 1st'Respondent u/s. 147 read with section 144Boi the lncome-tax Act Date of Order 12.03.2024, DIN. ITBA/AST/ Sl1 tl7 12023-241 1 O62426m4(d )for the Assessment Year 201 8- 1 9and all consequenti:rl proceedings pursuant thereto. IANO:1OFm26, Petition under Section 151 CPC praying that in the circumstances stated in the affidavit I'iled in support of the petition, the High Court may be pleased to stay all further proceedings, including any recovery, pursuant to theorder passed by the 1st Respondent uls. 147 r.w.s147 read with section l44Bof the lnoome-tax Act Date of Or<ler 12.03.2024, DlN. ITBA/ASTtSl147l2O23-2411O62426264(1ltor the Assessment Year 2018-19 and stay of Demand notice under section 156 \ 93 Dated. 12.O3.n24,vide DIN No.|TBA/AST/S115612A23-2411062426475(1) for the Assessment Year 2018-19, pending disposal of the writ petition. Counsel for the Petitioner: SRI THANhIERU CI-IAITANYA KUMAR Counsel for the, Respondent No.l & 2r SRI K.SUDHAKAR REDDY, Sr. SG FOR lT Gounsel'for, the Respondent No.3: Snl N.BHUJANGA RAO, ' , ,'' :DEPUTY SOLICITOR GENERAL OF INDIA . " ,...' aFltFn l?A6 hFhl 6At ^ t I Between lenu Ggpat_Eshwaroju, S/o. Prakash Eshwaroju Aged about 45 years, Occypatlqn. Buginess, R/o. H.No.18-6-1123, O/S GOWLIPURA Hyderabad 500053, Telangaha, lndia PAN.AAXPE2066M, Assessment Year. 2O2O-21 ...PETITIONER AND 1 Assessment :Unit, National Facetess Assessment Centre, lncome Tax Department, Ministry of Finance, Room No. 401, 2nd Floor, E-Ramp, Jawaharlal Nehru Stadiurn, Delhi -110 0O3.

#2. The lncorne Tax Officer, Ward 9(1), Hyderabad I T Tower, AC Guards, Masab Tank, Hyder:abad, Telangana-S0O004

#3. Union of lndia Represent by Secretary Ministry of Finance North Btock, New Delhl-110OOl ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit:filed therewith, the High Court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of WRIT OF MANDAMUS holding that the notice issued (JAO) by 2nd Respondent under section 148 Dated. 29.04.2024 vide Dl,N No. ITBA/AST/51148-1t2124-2511}64415725(1[or the Assessment Year 2O2O-2'1and the consequential order passed by the 1st respondent uls. 1 47 read with section 1448 of the lncome-tax Act Date of Order 12-12.2025, DlN. ITBA/AST/5114712O25-2611083628767(1)ior the Assessment Year 2O2O-21, as 94 arbifary, illegal, bad in law, void ab initio, violation of principles of natural justice -' apart-from violation-of-Artieles't4, 19 (1)(g):and 265 of -eonstitutisn-oJlndia apart from belng violzrtiv€ of provisions of section 148Aand seCtion 149 of the Act and also contrary tc, the circular issued by CBDT and provisions of section 151A of the Act, and consequently set aside the order passed by 1st Responderil u/s. 147 read with section 144Bof the lncome-tax Act Date of Oder 12-12.2025, DlN. - ITBA/AST/S 114'712O25-2611083628767(t) for the Assessment Year 2O2O- 21and ,;rll aaaa'aoanli,.l rl(.r t,r vwe dings-pu ^^6 ^- IA NO: 1 OF 20?9 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit liled in support of the petition, the l'.ligh Gourt may be pleased to stay all further proceedings, including any recovery, pursuant to theorder passed by the 1st Respondent uls. 147 read with section 144BoJ the lncome-tax Act Date of Order '12.12.2025, DlN. ITBA/AST/S/1 4712025-26110A3628767(1fior the Assessment Year 2O2O- 21for the Assessment Year 202O-21and stay of ,Demand 'notice under section 156 Dated. 12.122025 vide DtN No .ITBA/AST/S115612025- 26/1083628809 (1) fear the Assessment Year 2O2O-21, pending disposal of the wrft petition. Counsel for'the Petitioner: SRI THANNERU CHAITANYA KUMAR Gounselforthe Respondent No.1 & 2: SRI K.SUDHAKAR REDDY, Sr. SC FOR IT counset ror the Respondent No'3: SEiU#"'3tifrffi; NERTAL oF rNDrA o n Between: Mr. Siva ltami Reddy Gangi Reddy, S/o Mr. Rami Reddy Gangi Reddy, Occ. Retd. Railway Employee, Aged about 70 years Plot No. '54, 14-174154, Hi Tension Foad. Sainikpuri, Hyderabad - 500094, ...PETITIONER 95

#1. Union of lndia, Minsitry of Finance, Delhi, by its Secretary, Department of Revenue, 2 Assessment Unit, National Faceless Assessment Finance, Room No. 401, Delhi - 110 003. Jauaharlal

#3. The lnoome Tax Officer, Ward- 1{3), Hyderabad, LB Stdium, Basheer Bagh, Hyderabad, Telangana

#4. TheJoint Commissioner of lncome Tax, U/s 151 of Masab 13, Tax Opposite Petition under Article 226 of the Constitution of lndia praying"that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to pass an order br direction, especially one in the nature of WRIT OF MANDAMUS holding that the notice dated 23.06.2025 issued by 3rd Respondent under section 148 of the Act with DIN and NOTICE No.|TBA/AST/S1148 112025- 2611077il6000(1) as being without jurisdiction, arbitrary, illegal, bad in law, \roid ab initio, apart from being violative of provisions of section 148A and section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section '1514 of the Act, and consequently set aside the notice urder section 148 dated 23.06.2025 for asst. year 2O2O-21 . I 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 aH further proceedings pursuant to the notice under Section 148 of the lncome-tax Act, 196'l dated 23.06.2025 bearing DIN: ITBA/AST1S1148_1{2O25- 2611077516060(1) for the Assessment Year 2O2O-21, pending disposal of the writ petition. Petitioner: SRI S.N.S.R.CHINMAI Counsel forthe Respondent No.1: SRI N.BHUJANGA RAO, DEPUW SOLICITOR GENERAL OF INDIA Counsel forthe Respondent No.2 to 4: Ms. B.SAPNA REDDY, Sr. SG FOR lT 96 1 ...PETITIONER Between: AND

#1. Union _sf__lndia Jt/inislnf_olfinanqe,_ lncoEoe T€x epartment. Delhi- _ 10001 1

#2. The Office of Commissioner, lncome fai Oepartment tvtinistry of Finance, Govemment of lndia, New Delhi-100011. :

#3. Office of the lncome Tax Officer, Ward-l, Mahabubnagar lncome Tax ffice, Deo Office Road, Andhra Pradesh-509001

#4. The National Faceless Assessment CeRtre, lncomg Tax Department,'Ministry - offinance, Govemment of lndia, NewDelhFt000t-t " ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed thercwith" the tligh Court may be pleased to issue a writ or direction or order more particularly in the nature of a writ of certiorari calling for the records and quashing the (i) lmpugned Order dated 31.O3.2,)24 bearing DIN and Notice "No. ITBA/AST/F|14BN2O23- 241'1063744617(1) for the Assessrnent Year ?AZA-21, issued by the 3rd Respondent under Section 148A(d) of the lncome Tax Act, 1961 (ii) lmpugned Notice dated. 31.03.2024 bearing DIN No. ITBA/AST/51148_112O23- 241'1063748417(1') for the Assessment Y.ear nzA - 21, issued by the 3rd Respondent un, Cer Section 148 of the lncolne Tax Act, ,961 and (iii) lmpugned Orderdated.l 5.01 .2025 bearing DIN ITBA/AST/5114712O24- 2511072206167(1 ) passed under 147 read with section 144 read with section 1448 of the lncome Tax Act, 1961 as being illegal and in violation of applicabte law and consequently set-aside all consequenU subsequent notices/ orders and further restrain the Respondents fr, rm making any assessment, reassessment or re-computation or otherwise proce, eding against the Petitioner on the basis of the aforementioned lmpugned Orde.s and Notices. 97 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 suspend all furlher proceedings pursuant to lmpugned Order dated 15.01.2025 bearing DtN ITBA/AST/5|14712O24- 2511072206167(1) passe<l under 147 read with section 144 read with section 1448 of the lncome Tax Act, 1961 including all subsequent notices/ orders, in the interest of justice. a under Section 151 CPC praying that in the circumstance" "t"t"O in the affidavit filed in support of the petition, the High Court may be pkeased to stay the operation of the lmpugned Order dated. 15.01.2025 bearing DtN ITBA/AST/S/14712O24- 2511072206167(1) passed under 147 read with section '144 rqad with sectionl 448 of the lncome Tax Act, 196't, including all consequenU subsequent notices/ orders, in the interest ofjustice. Counsel for the Petitioner: SRI SHEETAL SRIKANTH Gounsel forthe Respondent No.l: SRI N.BHUJANGA RAO, DEPUW SOLICITOR GENERAL OF INI)IA Counsel for the Respondent No.2 to 4: SRI K.SUDHAKAR Sr. SC FOR lT , 0 1 e Bhaskar Rao Edala, S/o. Edala Varada Rao Aged about 64 Years Fl/o. Flat No. E3, President Ba njara Apartments, Road No.2, Banjara Hills, Hyderabad Telangana - 500034 R 'l . The National Faceless Assessment Center, lncome-tax Delhi, lndia Department, Nalr

#2. Assistant Commissioner of lncome Tax, Circte 3(1), Hyderabad Petition under Article 226 ot lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be 98 pleased to issue a writ, order or direction, more particularly in the nature of writ -- - of-mandarnus-<leeh rjng -ondeFunder-Seetiion *484(dr'ffied-30/eB/202karing- DIN: ITBA/AST/F/1 48N2O24-25lI068196094(il) and the consequent notice dated 3OlO8l2O24 u/s;. 148 bearing DIN: ITBA/AST,;/S1148=112024-2511068197860(1), as being void, illegal, arhitrany, without lurisAictlon, vi, olate of Article 14 of the Constitution of lndia and consequently set aside the same. {A NO: 1 OF 2026 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petttionl, the.F*igh Court may be pleased to stay all further proceedings pursuant to 'order, under Section 148A(d) dated 3}l}8l2o24 be, aring DIN ITBA/AST/F|148N?524-2511O68196094(1) and the consequent notice dated 30rc8nA24 u/s. 148 bearing DIN |TBA|ASTtstl4S_112024-2511068197860(1), pending disposalof the writ petition. Counsel ior ther Petitloner: SRF'filLIrfAGA DEEPAtr Counsel for ther Respondents: Ms. BOKARO SAPNA R.EDDY, Sr. SC FOR lT The Court made the follovtring: GOttlMOill ORDER IN TIIE IIIGH COURT FOR THE STATE OF TELANGANA AT TIYDERABAI) TTIE HON'BLE TIIE CHIEF JUSTICE SRI APARESH KT,IMAR SINGH AIYD TEE HON'BLE SRI JUSTICE G.M.MOHII'DDIN 4033 40491 40631 v5l 767 II 1211, 1265, 127q. 1275. 1410. 1441. 1459. 1464, 1467. 1469. 1504. I6E2. 16E3. 169l. 1754, 1757. lg0g, lgl4, lgl7. 1g2g, 1844. 1865 and 1914 of 2026 DATED z 27.01.2026 w.P. Between: Mohammed Ibrahim Ali ANI) Petitioner Assessment UniQ National Faceless Assessmrnt Centre, fncome TarDeparmeng Ministry of Finance, Delhi and two others ..Respondents W.P. No.40201 of 2025 Between: Suresh kumer Choudari Kopalli AIYD Petitioner \. \ Assessment Upit, fncome Tax Department, Nati, onal LAssessment Centrq Delhi and four others .Respondents z HCJ lAKrS, J) & cMM. J W.P.No.4Ol l8 of 2O25 and barch W.P. No.40230 of 2025 Between: Mr. Prabhakar Pokala I.ncome Tarx Oflice, Nalgonda Districg.and two others AND Petitioner .Respondents W.P. No,.40232 of 2025 Between: Vivek Ashwin Vanam AI\TD Fetitioner Assessment Unit, National Faceless Assessment Centre, Incomc Tax Deparlment, Ministry of Fhanccr Delhi and another .Respondents W.P. No.40242 of 2025 Between: Mohammed Ibrahim Ali A$II} Petitioner Assessmenrt Unit, National Faceless AssessmentCentrg. : Income Tar Department, Ministry of Financg . Dethi and two others ' .Respondents W.P. No.,40331of 2025 Between: / Tricolour I'roperties Private Limitcd, Rep., by its Authorizrd Signatory Mr. B. pFjdhav Assistant Commissioner of Income Tax, Central Circle3(l), Hyderafud and two others ANI) Petitioner / .R.espondents 3 ,rc., (Ar&s, q e GxM, J W.P,No..tOl la of 2GrS lrd batch mtB Between: Tricolour Properties Priv.te Limited, Rep., by its Autborized Signatory Mi. B. Medhav [NI]] Petitioner Assistant Commissioner of Income Terr Central Circle-3(l), Hyderabad and two othet! Between: Sai Kumar Thota Sai Kumer AI\D Union of India, Ministry of Finance, Income Tax Department, New Delhi and three othen No.40464 of Between: Swathi Guduri Petitioner .Rcspondents ANI) Petitioner Assessmena Unit, Income Tar Department, National e'Assessment Centre, New Delhi and two othert w No.40491 of Between: Suresh Tammineedi ...Respondents \ ANI) Pctitioner Union of India, Ministry of Finince, Rep., by its Sccretary, New Delhi and trvo othett ...Respondents + _ _ Hc, (Axrs,4 &-GMM, J W.P.No.4Ol18 oI2O2S and batch Uf .P. Nia.4OtL9} of 2fr25 Between: Concord Drrgs Limited, rep., by jits Authorized SignatoryrMr. Seelam Nagi Reddy AI\E) Petitioner Union of India, Ministry of Finance, Rep., by iits SecretaryrNcwDelhi and two others W.P. No.40493,of,2025 Between: Suresh T:tmmineedi AIYD Union of l[ndia, Ministry of Finance, Rep., W its Secretaryr, New Delhi and two others w.P. Between: Concord l)rugs Limited, rep., by its Authorizcd Signxory, Mr. Seclam Nagi Reddy Union of India, Minbtry of Finance, Rep., by its Socretary" New Ilelhi and two otters ATID w Between: Suresh Ta;mmineedi .Respondents Fetitioner .Respondents Petitioner Respondents Union of India, Ministry of Finance, Rcp., by itr; SecretaryrNewl)elhi and two others AIYD Petitioner ...'Respondents / r' 5 HcJ ( X.S, { & cXX, J W.P.No.4OllA ofarts end berch W.P. No.40496 of 20D5 Betreen: Concord Drugs Limited, rep., by its Autborized Signetory, Mr. Sedam Negi Reddy Union of India, Ministry of Finrncc, Rep., by its Secretary, Nen'Dethi end two.o&err ANI' W.P. No.4061Oof 2U25 Between: Mr. Balarami Reddy Muli The Income Tex OIIicer, lYard I4(1), Hyderabad and three others AND W.P. No.406ll of 2025 Between: Sistu Krishna Rao ... Petitiotrer Respondents ... Petitioner ...Respondents ANII ... Petitioner The Natioml Faceless Assessm€nt Centre, Income.tar Department, New Delhi end three others ...Respondents W.P. No.406l5of 2025 Between: Venkata Subbi Reddy Penumallu A}ID, ... Petitioner AssessmeDt Unit, Income Tar Departmetrt, National e'Assessment Centre, New Delhi end four others ...Respondents 6 IIC., (AKrS, 4 & cMM, J \t/.P.No.zOl l8 of 2O2S and batch W.P. Nol{629 ot2L?5 Between: DCS Limited, rep, bi ils Anthdriietl Signatory V. Sridhar ANI) Petitioner O-ffrceattb, eAsblant--C-ommissionerof C.entral (lircle2(3), Income Tax Department, Hyderab, erd and. two others IncomeTax, W.P. Nor40631 of 2025 Between: Pranathi .[danchukonda AND Assistant Commtssion of Income Tax, Ceotral Circle.3(4), Hyderabad and four others Between: Narayana Ravisetty The trncorrre Tax OIIicer Ward-l, Aditabad, Telangana andtwo others AND W.P. No.40638 of 2025 Rcfrrraan. lVfubeen Khan AI{D The Income Tax Oflicer, -Ward-7(l)., Hyderabad and three others ...Respondents Petitioner .Respondents Petitioner ..Respondents Petitioner t J .Respondents 7 HC.' (AIkS, J' & GMM, J W.P.Lo.,'()llAof 2(,l5 .'rd barch W.P. N Betrveen: of2025 Surendre Mth Chorrdary Pathuri AND ... Petitioner The Income Ter Olficer, Ward (Circlelll(l), Hyderabad end two others W.P.No.40658 of2025 Between Mardhani Shokat Bhai Income Tax OIIicer, Circle-8(l), Ilyderabed, Signalure Towens, Kondapur, Hyderebad andtwo others ANI) W.P. No.40722 of 2025 Between: Srinivasulu Vallamkonda The Income Tar Olficer, Ward-l, Income Tax Olficer llanamkonda, Warrngal and two others AI\D . . .Rcs jrondents ... Petitioner ...Respondents ... Petitioner ...Respondents W.P. No.40734o12025 Between: Tricolour Properties Private Limlted ANI) ... Petitioner ( t Assistant Commissioner of Income Tax, Central Circle3(l), Ilyderabed and two others ...Respondents I Hc..I (Ar(6, Jl & cMM, J W.P.No.4Olt8 itf 2O2S and'batch /-- W;P- $ o.40788-of-20il5 Between: Gayatri Devi Davuluri AI\TD ... Petitioner Assessment Unit, National Faeelessdssessmrent Contrq, -Ircufie"TexDep-a-rmrcn[-Ilfinftirrydf Tlnance; New Delhi and'two othem .Respondents W'.F. No.40805 of 2025 Betweenr Burugula Raji Reddy AIYD Patitioner Assessment Unit, National Faceless Assessment Centre, Incorire{ax Department, Ministry of Finance, Delhi ahd two others .Respondents AND Petitioner lUb !w.r. l\ A G ot Lvzo ' Between: Mr. Nasar Bin Salem Babader The'fncome Tax Officer, Ward 9(l), Eyderabarl and another W"P. No ?etweenr of 2026 t Tricolour Properties Private Limited, Rcp, by its Authorized Signatory- Mr. B. Madhav Assistant Commissioner of Income Tax, Central Circle - 3(l), Hyderabad and two others AIYD ...Respondents Petitioner ...Respondents 9 Hq, (Axrc, 4 & cMx, J W.P.No.4ol Ia of 2OAS alrd brtch w.P. Between: Tricolour Properdca Privite Limited, Rep., by its Authoriad Signatory - Mr. B. Madhav AND Petitioner Assistant Commissioler of Income Tax, Centrel Circte - 3(1),Ilyderebad end four others Between: Tricolour Prcperties Privete Limited, Rep., by its Authorizcd Signrtory - Mr. B. Madhav , AND Assistant Commissioner of Income Tar, Centrrl Cir, cle - 3(I), Hyderabad and four olhen Between: Tricolour Properties Private Limited, Rep., by its Authorized Signatory - Mr. B. Madhav Petitioner Respondents ANI) Petitioner Assistant Commi*ioner of Income Tar, Centrrl Circlc - 3(I), Hyderabad and four oahers w.P. Between: Santosh Kumar Siga \ The Government oflndia, Ministry ofFinance, Income Tar I)epartment, rep., by its Principal Secrctary, New Delhi end two others ...Respondents ANI) .." Petitioner 10 HcI {AxrS,_JI& cMM, J W.P.Ito.,fOl l8 of 2(D5 and batch IV.P.f{o-629-cf 202-6. Between: Mrs. Ush:r Rani Thaduri Ar{I) Petitioner The Assistant Commissioner of Income Tax, Circle-1, Karimnagar and four others W.P. No.636 of 2026 Between: Rami R.eddy Gopireddy AIYD Petiaioner Assessment Unit, National Faceless Assessment Centre, Income T:rx Department, Ministry of Finance, Delhi and two others .Respondents W.P. No.646 of 2026 Between: The Agricultural Cooperative Credit Society Meenavolu, Rep.. by its Secrctary Nalajala Rambabu AND Petitioner Assessment Unit, National Faceless Assessment Centre, Income Tax Department, Ministry of Finance, Delhi and two others W.P. No.707 of 2O26 Between: Tricolour )lroperties Private Limited, Rep., by its Authorized Signatory - Mr. B. Madhav Assistant (lommissioner of .fncome Tax, Central Ci;rcle - 3(l), Hyderabad and four others ANI) .Respondents Petitioner ..Respondents a 11 HCJ (AxrS,4 AG M,J W.P.No.4OI la of 4,l5 and b.tcrh W.P. No.743 of 2O26 Between: TricolourPnopertie Privnte Limid, Rep., by its Autboirized Signatory - Mr. B. Medhav AND Assistert Commissioner of Income Tar, Centnl Circle - 3(l), Hyderebad and four others W.P.I{0.746 of 2026 Between: Tricolour Propertica Privete Limited, Bep., by its Authorized Signatory - Mr. B. Madhav ... Pctitioner Respondents AND ... Petitioner Assistant Commissioner of Income Tax, Centrel CircIe - 3(1), Hyderabad and four others ...Respondents W.P. No75l of 2026 Betweeo Mohammed Hidayathuddin AIID Petitioner Ass€ssnetrt Udt, Netional Faceless Assessment Centre, Income Tax llepartmcnt, Ministry of Finance, Delhi and two others 2026 W.P. No767 Between: Tricolour Properties Private Limiaed, Rep, by its Authorized Signatory - Mr. B. Madhav Asshtrnt Commissioner of Income Tax, Central Circle - 3(l), Hyderabad and four others ANI) ...R6pondents ... Petitioner ...Respondents \ L t2 _ . HC.' (ar(ts,J}.&, cMM, J W.P.No.4O I 18 of 2OirS erd batch Between: Smt Karuna Shett5r ANI) Petitioner Assessm, ent Unit, National Faceless Assesmetrt Centrc, Incomc '[ar Department, Ministry of Financq Delhi and another W.P. No.Il74 of2026 Between: Tricolourr Properties Private Limited, Rep.' by its Authorized Signatory - Mr. B. lldadhav ...Respondcnts ANI) ... Petitioner Assistarl Commissioner of Income Tax, Central (:ircle - 3(I), Hyderabad and four others W.P. No.ll98 of 2026 Between: Nandyal '[rading Private LimiGd, Rep., by its Director - Angitaprlly Sreenivasulu Reddy . . .Respondents ANI) .., Petitioner / Assessment Unit, National Faceless Assessment C€ntre, Income T:rx Department, Mids(ry of Finance, Delhi and two othens W.P. No.l2 ll of2026 Between: Mr. Mohammed Azeemuddin Azam Assessment Unit, Nalional Faceless Assessment Centre, Income Tax Department, Ministry of Finance, Delhi, and another ANI) . . .Respondents ... Petitioner ... Respondenls 13 IlC, (AX'A, 4 & GMM, J W.P.Io.4Ol l8 of2ol5 ond hotch No.l265 o12026 Between: Tricolour Propertiei Privete United, Rep. by its Authorized Signatory, Mr. B. Madhav ANI) Assistent Commissioner of Income Ta! Centrel Circle3(l), Hyderebad, and two others w.P. No.1270 of 2026 Betreen: Sri Venkatesware Rao Tammineni The Income Tax Ollicer, Ward-I, Income Tax Ollice, Khammam, and another AI\ID W.P. No.l275 of 2026 Between: Sri Nagunoori Damodar AND The Income Tax Officer, Ward-I, Income Tax OIIice, Warangal, and another W.P. No.l4I0 of 2026 Between: Mr. Jallapuram Narsing Sridhar Petitioner f ... Rerpondents Petitioner Respondents ... Petitioner Reapondents AND ,.. Petitioner \ National' Faceless Assessment Centre, Ministry of Finance, Delhi, and another Recpondents t4 HCJ lAr&S,.J) & cMM, J W,P.No.4ol18 of 2025 ard barch W.P.No-I441 of 2025 Between: Mr. Sye'd .Abdul Bari AI{D ... Petitioner Assessment Unit, Nstional lhceless A-sgessment Ccntrc, Income T:rx Department, Minijtr5r of Finance, Delhi, and trvo others W.P. No.l45E of 2026 Between: Mrs. Medikonda Bhaveni ... Respondents AND ... Petitioner Asscssment Unit, Netionnl fhceless Asscssment Centre, Income Tax Department, Ministry of Flmnce, Delhi, end two others W.P. No.l464 of 2026 Between: Tricolour )Properties Private Limited, Rep. by its Authorized Signrtory, Mr. B, Madhav ... Responrlcnis AND ... Petitioncr Assistant (lommissioner of Income Tgr, Central Circle-3(l), Hyderabad, endtwo others W.P. No.I467 ot2026 Between: Tricolour I'roperties Priv.te Limited, Rep. by its Authorized Signatory, Mr. B. Madbav Assistant Clommissioner of Income Tax, Ceotral Circle-3(l), Hyderabad, and two.otheE AM} ... Respondents ... Petitioner t ... Respondenls a-. 15 ffC; 6r<tS,.4 e C'ri[l,t, J W.P.No.40l l8 of 2(D5 and batch WrP. No.I469 of 2026 Between: Tricolour Properties Private Lirnited, Rep. by its Authorized Signatory, Mr. B. Madhav AI{D Assistant Commissioner of fncome Tax, Central Circle3(l), Hyderabad, and two othen Petitioner Reepondehts W.P. No.I,504 of 2026 Between: IVI/s. Primary Agricultural Cooperative Credit Society Limited, Lingampet, Rep. by Mr. Pulgala Pentaiah i _ AIYD Fetitioner Assessment Unit, Incomc Tax Department, National eAssessment Center, New llethi, and three others W.P. No.1652 of 2026 Between: Trieolou r Properties Private Limited, Rep. by its Director Mr. Chandan KumarJha AIYD Assistant Commissioner of fncome Tax, Central Circle3(l), Hyderabad, and five others W.F. No.t683 of 2026 Between: Shubhanand ini Infrastructures, Rep by its Managing Partner, Mp. Koudagani Rambabu The Income Tax OIIicer, Ward-l, Warangal, and two others AND Respondents Petitioner Respondents Petitioner Respondents \ \ 16 HCJ {AxrS, J} & cMM, J W.P.No.4Ol 18 of 2O25 and batch W.P. Ncr.1691 of 2026 Between: BIEqCS _Li-i_!gd, Btpge Rg0.dy:.DjsEi_p$, .- Rep. by its Secretary, Mr, P. Murali Krishna AND Petitioner Assessmerrt Unit, National f'aceless Assessment Centre, Income Trx Departmeht, Ministql of Finance, Delhi, and another W.P. Nc,.1754 of 2Q26 Between: Tricolour Properties Private Limjted, Rep. by itsr Director Mr. Chandan Kumar Jha AIID Assistant llommissioner of Income Tax, Cent ral Cii rcle3(I), trIyderabad, and ;five others W.P. No,.1757 of 2026 Between: Mr. Giridhara Rarna Kum-ar, S/o late Ctr. V. Satyanaraylna Murthy, Respondents ... I)^i:+:^-^- l GAlltullEl Respondents ANE Petitioner Assessment Unit, Income Tax I)epartment; National e-Assessment Center, New Delhi, and four others / / Respondents t7 . HqrGXrq4&cMM,J W.P.No.ztol18 of 2O25 and batch W.P. No.1809 of 2026 Between: Tricolour Properties Frivate Limited; Rep. by its DirectorMr. Chandan KumarJha AND Petitioner Assistant Commissioner of Income Tax, Central Circle3(l), Hyderabad, and five othels W.P. No.1814 of 2026 Between: Sripathi Venkata Rama Subrahmanya Sripada .;. Respondents AIYD Petitioner National Faceless Assessment Centre, Delhi, Ministry of Finance, New Delhi, and another Respondents W.P. No.18l7 of 2026 Between: Jawaharnagar Ed ucational Society, Rep. by its Principal, Mr. Kasula Venkata IYarasimhaReddy AND Petitioner Assessment Unit, National Faceless Assessment Centre, Income Tax Department, Ministry of Finance, Delhi, and two others Respondents \ \ 18: . Hq, {AfrS,4 &GMM, J W,P.No.4Ol l8 of 2025 and batch Between: Venu Gop, rl Eshwaroju AND Petitioner Nalioualfheelec@ Income Tax Department, Ministry ofFinance, Delhi, and two others W.P; No,;tr844 oJ2026 Between: Mr. Siva ttami Reddy GangiReddy Respondents AND Petitioner Union of India, Rep. Dy ilerSecretar?r I)epartmernt of Renerue, Ministry of, Finance, New, Delhi, and threeothers W.P. No,.1865 of 2026 Between: Mr. Srikanth Goud Ar,ra Respondents ANI) Petitioner Union of lindia, Ministry of Finance, Income Tax l)epartment, New Delhi, and three others Respondents ) J 19 HC.r (ArGS, Jl& CMM, J W.P.No.z0l 18 of 2O25 and batch W.P. N9.1914 of 2026 Between: Mr. BhaskarRao Edala AI{D ... Petitioner The National Faceless Assessment Centre, Income Tax Department, New Dethi and another Respondents COMM ORDER: Heard learned counsel - Mr. T. Chaitanya Kumar; Ms. Akruti Agarwal; Mr. Dundu Sashank for Mr. Dundu Manmohan and Mr. T.V.L. Narasimha Rao; Mr. Singam Srinivas Rao and Mr. Vighnesh Asawa for Mr. A.V.A. Siva Kartikeya; Mr. Santosh Sagar Kapilavai; Mr. Sheetal Srikanth; Mr. Paturi Rama Krishna; Ms. Sneha Asthana; Mr. Kailash Nath P.S.S.; Mr. Sandeep Sripada for Mr. Karan Talwar; Mr. P.Soma Shekar Reddy; hzlr. Mohammed Rafi for Ms Shaik Vaheeda Sushma; Mr. Parikshith Kutur; Mr P. Rama Sharana Sharma; ndr. A.V. Raghu Ram; Ms. Syeda Sajida Samareen Fatima; Mr. S.N.S.R. Chinmai t and Mr. M. Naga Deepak, appearing for petitioners 20 HC.r lAKrS, Jl & cMM, J W.P.No.z0l 18 of 2O25 and batch AIso *reard Ms.- +.-Suftitha; -Ms, Bokaro- -Sapna teddy; 'Mr. N. FraVeen RedAr;N[r;VijherK. Punna, Mr. K-. Sudhakar Reddy, learrred senior standing counsel appearing for Income Tu< Dr:partment; 'It{rs. B. Kavita yadav, rearned senior -stantling (5unsel.- apparin[ for ceniral Government and h[r. N. Bhujanga Rao, Ieamed Deputy Solicitor General of Ir,d;ia ap, pearing for Union of India. 2- In all these writ Petitions, the challenge is to the initiation ofprooeedings under Sections 148(A) and l4g of the Income Tar Act, 196l (fo. short, "the Act,,) by the Jrrisdictional Assessing Offi cer (JAO) 3 Petitior'rers though have taken other pleas in most of tlrese W:rit Petitions, they submit that the issues involved in the present batc*r of Writ Petitions have been considered and settled in the- order dated 28.04.2025 passed by the learned coordinate Bench of this courr in w.p.No.26304 of 2024 followin;g the decision rendered in the case of Kankanala 2L Hqr (AXrS,4 lll.P.No.ztol 18 of 2o2S &GMM,J and batch Ravindra Reddy ys. rncorne Tax ,officgrt. It is subrnitted that the present Writ Fetitions may be disposed of on same lines after setting aside the :impugned proceedings under Sections 148(,4.) and 148 of the Act and on similar terms as are set out in the case of Kankanala Ravindra Reddy (supr4 and also in the order dated 28.M.2025 in W.P.No26304 of 2024.

#4. In support of the sub, missions made by the learned counsel for the petitioners, they relied on the judgments of Bombay High Court in Ilexaware Technologies Ltd., vs. Assistant Cornrnissioner of Income Tax and others2l Abhin Anilkumar Sah vs. Inco, me Tax Officer (International Taxation) and others3; Bank of India vs. Assistant Cornmissioner of fncome Tax and othersa; judgment of Gauhati High Cotrrt in Rarn Narayan Sah vs. Union of India and otherst, judgment of Punjab and Haryana High Cgurt in Jatinder Singh Bhangu vs. Union of India and others6, ' QOZS) 156 taxmann.com 178 (Telangana) 'eozq 464 ITR 430 (Bom) ' (2024) 468 ITR 350 (Born) o lzozay 468 tTR 350 (Bom) t.eozq4zl ITR 228 (Gauhati) '(2024) 466 lrR 474 (p&H) 22 llcJ (AKrS, Jl & cMM, J W.P-No.40l l8 of 2oi25 and batch judgments-,of Telangana High eourt in-Venletaramana Reddy Patloola vs. Deputy Commissioner of rncome Tax and othersTl sftail( saiid vs. Assessment unit, rncome Tax Department tnd, ot#;*KiEgs ?fiAe- Infit ProjectC (ry Ltil., vs-J DCpniy , The Assistant Commissioner of Income Tax, Ward 6(Ui Hyderahad"; and Deloitte Consulting India (P) ttd", vs. Assessment Unit, Income Tax Departm..nt", judgrnent of Himachal Pradesh High Court in Govind Singh vs. Ineome Tax officerr2; judgment of Gujarat High court in Mansukhhhai Dahyahhai Radadiya vs. Income Tax Officer, Ward 3(3)(5)rii judgment of Jharkhand High court in shyam sunder saw vs. " union of, rndia and othersta; judgment of calcutta tligh Court in Ghidhar Gopal Dalmia vs. union of India and othersrl, judgrnents of Madras High Court in TVS credit services rrtd., '.p0221468 ITR I 8 I (Tetangana) e W.P.No.2(i885 of2024 e- I 76 raxmann.com 704 (Te tangana) -1ZOZS1 ro w.P.No.2l o63 of zo25 & batch 'ltZOZS) 173 taxmann.com 781 (Telangana) " (2024) l6:i taxmann.com I I3 (Himachal pradesh) '.'.(2024) SCC Online Guj 4012 1z0zsl SCC Online lhar ZB7 15 MATNo. t6go of 2023 (DB) / / 23 HC.' (Ar&S, J)& GMM, J W.P.No.4Oll8 of 2O25 and batch vs. Deputy Commissioner of Ingome Taxl6 and Mark Studio India kt., Ltd., ys. Income Tax Officer and anotherlT, judgrnents of Rajasthan High Court in Sharda Devi Chhajer vs. Income Tax Officer and anotherls and Shree Cement Ltd., vs Assistant Commissioner of Incorne Taxle, and judgment of Karnataka High Court in'Ramchandra Reddy Ravi Kumar ys. Deputy Commissioner of Income Tax20.

#5. These matters have been clubbed together for the reason that all of them'assail the proceedings initiated under Section 148(A) followed by notice under Section 148 of the Act for reopening the assessment by JAO. The dates of the impugned notices and proceedings have been referred to in the individual Writ Petitions, which are post 29.03.2022 i.e., the date on which the Central Government, in exercise of the powers conferred under Section I 5lA of the Act, has made the 1zo2S1l74 tanrnann.com 1078 (Mad) (SB) t6 " w.A.No.78t of2o2l @B) 't 1zuzs1477 trR22s (Raj) " IzOZS'1I77 taxmann.com 538 (Rajasthan) 20 1zozs1 I 70 taxmann. com 422 lnombayl \ \ 24 Hq, 6xra, J)& c.MM, J W.P.No.4Ol 18 bf 2O25 and.batch e-Assessreftt of Ineorne Eseaprng Assessraent Scherire, Zilaz rride'Ncitificatibn Nbl I I of f022.

#6. The Dgpg@ent was askod -ts: -qbtain ihstructions and file countei-affidavits; if neiCisary, on facts and legal issues which are raised herein.

#7. Ttte learned Senior Standing counsel for the respondent Departmrent had obtained instmctions in aH ,these matters. Based upon the instructions received from the Eepartment, learned counsel for the respondents do not dispute that the in-itiation of impugneci proceedings under Section las{A} of the Act has been done by JAo after coming into forc-e of the Faceless Scheme with effect from 29.03.2022.

#8. The learned senior Standing counsel for the respondents have also not been able to dispute that the legal issues as regards the jurisdiction of JAO to initiate proceedings instead / / of Facek:ss Assessing officer (FAo) have been well settled by the coc, rdinate Bench of this Court vide order dated 25 HC.' (Arts, J' ri GMM, J W.P.No.4Ol lA o(2025 lnd b.tch

28.04.2025 in W.P.No.26304 of 2024 and followed in several otherjudgments.

#9. The leamed Senior Standing Counsel for the respondents also do not dispute that other jurisdictional High Courts have also taken the same view. However, they submit that a contrary view has been taken in the following decisions as well. In support of their submissions, they relied upon the judgment of Bombay High Court in Caishen Enterprise LLP vs. Assistant Commissioner2r, judgments of Madras High Court in Mark Studio India (P) Ltd., Vs. Income Tax Olficer22 and Perur Builders (P) Ltd., Vs. Income Tax OIficer23, judgment of Grfjarat High Court in Talati and Talati LLP vs. Assistant Commissioner of Incorne Tax2a and judgment of Delhi High Court in T.ICS. Builders (P) Ltd., vs. Income Tax Officer2s.

#10. The learned Senior Standing Counsel for the respondents submit that SLP(C).No.027736 of 2023 and batch challenging \ 2' 2 1zws1 176 taxnrann.com 47t (Bombay) 1zl2l1 169 taxnann.com 542 (Madras) 12025; 175 raxmann.com 253 (Madras) u 1Zel\rcT attaann.com 371 (Gujarar) " (2074) 167 taxntann.com 759 (Delhi) 26 Hq, (AXIS, J).& CMM, J It .P.No.4ol 18 of 2025 ard barch the ordt:rs passed by this Court and other jurisdictional High Qourts rrre pendinf bCfore the-Honble Suprbrie eour{ but no stay of r:he impugned judgments has, been granted in favour of the revenue. ll. We have considered the submissions of the leamed counsel for the parties and also the relevant factual assertion made bli the petitioners that the impugned proceedings have been initiated by JAO after coming into force of the Faceless Scheme with effect from 29.03.2O22. The relevant details concerning individual petitioners are appended to this order and shall be treated as part of the order. Th"y indicate the relevant assessment year, the date of notice issued under Section l48A of the Act, the date of the order under Section 148 of ti.re Act, the date of sanction under Section l5l of the Act, intimation to proceed with assessment under Section l44B of the Act, the date of assessment order as against the individual writ petitions refered to in Column No.l. II 27 HC!(AI&S,J) W.P.No.,lOl18 of2o25 &GMM,J ard'batch

#12. Frorn a,perusal of the tabulation chart, it is apparent that the impugned proceedings in all these cases have been initiated by JAO after coming into force of, the Faceless Scheme with effect from 29.03.2022.

#13. The legal issue as regards the track ofjurisdiction on the part of JAO to initiate the proceedings post implementation of the Faceless Scheme is no longer res integra as it has been held in the case of Kankanala Ravindra Reddy (supra) and by other jurisdictional High Courts.

#14. As a matter of fact, severat orders following the ratio rendered in the above cases have been passed one after the other. T,herefore, we are of the considered view that the present batch of Writ Petitions also stand covered by the decision rendered by this Court in the case of Kankanala Ravindra Reddy (supra). The relevant extract of the order dated 28.A4.2025 passed in W.P.No.26304 of 2V24 is reproduced hereunder: 28 - -+ICJ'(Ai<rS;Jf& GMM;J -- - W.P.No.4Ol 18 of 2O2S and tatch fur, ther '1"5. what is worry-ing this Beneh more is the-fact that an erdeavour is being made whole.heBrtedly to ensute noA to generat€ lit.igation on issues which have been laid, to rest by a large number ol'High Courts all of whom'have taken a gonsistent stand that the action of the Income Tax Departrnent being violative"of the Finance Act, 2020 and Finance Act 2021. Now, in order to protect the interest of the Revenue as also that of-the assessee, it wourd be trite at this juncture, if -we .dispose of- the writ -:petition with an observation/direr:tion that the disposal ofthe instant writ petition in terms of the judgment rendered by this ltrigh court in the case of K,mkanala Ravindra Reddy vs. Income Tax Officer |(ZOZ3) 156 tamann.com 178 (Telangana[ shall honever bp subject to the oLrtcome of the SLPs which were filed by the ,Income Tax Dr:partrnent and which is pending eonsideration before the Hon'ble Supreme Court. l1- So far as the interest of the Revcnue is concerned, we are of thr: considered opinion that the interest of.the Revenue has already been considered and protected, as has.been obsened in paragraphs 36, 37 and 38 of the or, der which, for ready referenee, is reproduced hereunder:

#36. For all the aforesaid reasons, the irnpugned notices issued and the proceedings drarnn by the respondent- Department is neither tenable, nsr sustainable. Ihe notices so issued and the procedure adopted ,being Wr se illegal, deserves to be and are accordingly set aside/quashed. Ai a consequence, all the impugned orders getting quashed, the consequential orders passed by the respondent-Department pursuant to the notices issued uniler Sections 147 and l4g would also get quashed and it is ordered ig_o_$itgly-., Thg rea5oh wd a-re-quashing-iheconsequenaitl ord;i G on itri principles that when the initiation of the proceedings itself was procedurally wron& the .subsequent orders also gets nullified automatieally.

#37. The preliminary objection raised by the petitioner is sustained and all these writ petitions stands allowed on this very jurisdictional issue. Since the impugned notices and orders are gefting quashed on the point ofjrrrisdiction, we are not inclined to proceed further and decide the other issues /I 29 Hq, {AXrS, Jl & GMM, J W.P.No.rEl 18 of 2025 ard batch raised by the petitioner which stands rcserv€d contended in an appropriate proceedirrgs. to be raised ard

#38. Since the Hon'ble Suprerne Crurthadl ln the cese of Ashish Agarwal, suprq fUnior of tndia r.' 456iil dgqwal [20221444 ITR I (SC)],as a one-time rneasur€ exbrcisiqgdre powers unden Article 142 of the Constitution of .krdig permitted the Revenue to proceed under the sutxtit t provisions, and this Court allowing the petitions only on fte procedural flaw, the right oonferred on tlre Rercnte u/ould remain reserved to proceed furttrer if they so want &om &e stage of the order of the Suprerne Court in the case of Ashish

#18. We would only further like to make observations d,rat shce we are inclined to dispose of the instant writ petitiorL corsoious of the fact that the earlier order of this High Court in the case of Kanakala Ravindra Reddy (l supra) is subjected to challenge before. the Hon'ble Supreme Court in SLP No.3574 of }}Z4,preferrod.by the lncome Tax Department, we make it clear that allowing of the instant writ petition is subject to outcome of the afor€said SLP preferred by the Revenue against the decision of this High Court in the case of Kanakala Ravindra Reddy (t supra). This, in offrer words, would mean that either of the parties, if they so wan! may move an appropriate petition seeking revival of this writ petition in the light of the decision of the Hon'ble Supreme Court in ttrc pending SLP on the very same issue.

#19. Accordingly, the instant writ paition sfands allowed in favour of the assess@ so far as the issue of jurisdiction is concerned. As a consequence, the impugned notice under otrattenge under Sections 148-A and 148 stands set aside/quashd. The consequential orders, if any, also stand set aside/quashod in similar terurs as have been passed by this High Court in the case of Kankanala Ravindra Reddy (l supra). There shall be no order as to costs." \ t \ \ 30 HC, (AKrS, Jl & cMM. J W.P.No.4Ol18 ot2O2S and batch 15- Thr: impugned prrrceedings under Sections l4gA and 148 of ttre Act 4ssailed in these rs/rit petitions ar€ set aside. The cons, equential ordens, o*r- also stand set aside on similar terms as held in the case of l(ankanala Ravindra Reddy (supra). fhe revenue is atrso granted lib".ry in the same terms as at para l8 of the above quoted ordbrs.

#16. Acc:ordingly, the iasanr'w-rit, petitions are disposed of. There shall be no order as to oosb. Misogllaneous applications,' if any pending, shalt stand closed. I / / f 31 Hc..I (Ar&S,Jl &cMM,J l[r.P.No.z0l 18o[2025 and batc*r E Ce:c IIo. /f.rc af, uc C6!b Ftled or lfot Ast. Yr Inb. RaG.bad Ifotlcc u/r 'Detcllf l{otlcc n/r t4E:r{bl D.tG,of ,.Orrlq.nfr. r.tS'rl{dl Dete of '8;nictloa u/r 151 Inttnr. t,,l. 144 B Ir.tc cr.rlAl Odet Detc of As Eat (Her h., u.ls 25,() ofLT Act Surceh Kumr Clroudar v Komlli Mr. Prabhak t Pokala Vivek Ashwin Vanarn Sai Kumar Tbota Sakum r Swathi Grduri wP/r020 lt202s wP/(J,23 on0rs WP 40232nO ,5 WP/ilO,l2 wP/4046 4tm2s 38 10 1t t!8 49 ritPtl0/g tno2s wP/t049 2no2s 50 5t Suresh Tammin Concord Drugs Limited. NOT FILED 2014-t 5 FII -Et) ,6ro-ro WP/ttO'|g 1no2s wP/40{9 1DO2s s7 5_l Surcsh Tmrnin *l; Concord D'ugs Umital 20t 5- l6 FILED mtr-18 l,lOT FIT-ED NOT FILED NOT FILED NOT FILED 202G21 I^TTUS 3143-2024 ot.ll8-202s iTas 20r 7- r8 RMS 294t-)OrS 7ll-Y]F[ttR 20rq20 29{3JO21 2021-72 RMS 26M-)A7S FII-F,D 202G2t ITUEJ Ashish Agarwal, Civil Appeal 30051202 2, datod 4th May, 2022 RMS Ashislr fuarwal, Civil Appeal 300sno2 2, datcd 4rh May, 2022 RMS Ashish Agarwal, Civil Appcal 3@5rm2 2,ililed ilth May, 2022 M{3.2024 ,M0t tt t 2647-2fJ2) t644-2024 2943-10?I 2647-)Or2 1641-2021 lri(-rmt tM5-ror1 ,8,41-AOD 2x.o1.2{Jf22 r ri3Jt?i mt7-la FILED 202G2t RMS ts41-4(J21 2A4aafirl $ia-ran NOT FII-ED NOT FILED mt6-17 RMS o!41-m24 ,atR-to RMS 2948-2024

06.08-2024 x'48-2{J24 mrL)t RMS t544-2024 2841-2024 $4-n24 20r 7-r8 RMS o741-)0)4 os4)4.)21 0741-rO24 20{i).&25 wP/tu9 sno)s wP/4049 6tm25 wP/406t Mn)1 WP/,1O63 8no2s ltE t$7uno ,s wPrst/2 026 WP llM/202 6 i! 55 56 62 67 Suresh Tammin c€di Concord Drugs l-imirdl Balarami Reddy Muli Mubccn Khan Gafalri Dcvi Davuluri Molurn I{idayath 'Smt. lGruna Shcfly 32 HGJ (AKrS, Jl W.P.No.4Oll8 of2O2S &GMM,J and batch -i l -lq.l 98 r0t ro:l t.08 WP 1275D02 wP/1410/ ,(J26 wPn6t3/ m26 WP fi371202 5 WP/ltt'l/ 2026 wP/l9t{/ m26 Sri Nagtuloo n Damoda Shdhan Infrrstru cOlGS Crirftfiur a Rema Kumar &ipdti Vq*rta R.ma Subrthm Srioda Bhask r Ro F,l^1, ' },IOT FII-ED tot6.n nMs tt{t3-2023, l ,rot?-t8 ntu*-s t tw-zvn ,O45.2t 2 mr 6lal nIV(q "t,}2ft-at not 6lcd 'ntLto mt fiIGd :nl8-r9 ftYri d{it u.$tt}m ,M1}/-rora EIi!-fEm trfriff'rn 30{&2024 t2ar-frr1 v$rErin zLoi-zxul aILlr:mo wP/{33 tno25 46 Tricolour Proedricr Iinird No( Filed S€.rch ml7-t8 79,-lr, firl 20-t2-2021 I t.nlrora wP/403l 1no)\ 4't T,ioolarr Propcrri6 I imial Not Filcd ,ot9-20: Scath d<tta mliffrtll 30{l-2023 ro-0r-rora wP/r061 lDO7S Pr.n hi [l{aochu Not Filcd wfd4 Scar'* r*tirtla a I r t41-2fit5 6 wPt1073 lnor5 Tildm PtoFri6 fiDit d Not Filed Scatfi ml&t9 ,a.12:2ca )o-t)-)o)\ I t Jl-rcld wP/81120 26 70 Tricobur ProFtics Umirod Not Filed ao2o-2t sAdr r/s 132 0:Lr0-2023

2249.2023 3l{l-2t24 t545- 23-10- Ycs (oldcr b pessd' cn(A ) dirtris dE Y.cs (otder b cn(A ) dismis (OdGr b Uy cTt(A )pdtly ilorri ngdE (Od.r b pe6sd w crT(A ) dismis Ycs (frcr Fssd cn(A ) dismis 33 HC.J (ArkS, Jl W.P.No.aOt16 of 2o,25 &GMM,J and batch Ycs (Oid€r possed cm(A ) dismis dE Y6 (Ordcr crT(A ) dismis Y€s (Oidcr passod cn(A ) dismis sinS rDoed Y,cs (Order passed cn(A ) dismis Ycs (Ordcr parscd w cn(A ) disrnis Yes (Ordcr paiscd cn(A ) disrnis aDocal Yes (Order parsed c[f(A ) dismis t54r-fr21 0549-2021 06{,-m24 06n9-2024 mn?L /lm-*Dt ,]I6,{le-2fr.,1 wPnTno 26 7l Tricolour Not Sarch wPt249t2 026 72 Tricolour Propqrici Limir.d No( Fild mm-21 Scardl u/s 132 wPt254t2 026 73 Triolour Propqtics Limitcd Nor Filed 20t8-19 Scarch u/s 132 wPn07t2 o26 78 Triolor PrcF[rcs l-imitcd Nor Filed 10r 7-18 Scarch u/s 132 wPn4y2 026 79 T.i@kpt Popcdics Ljmitod Not Filcd 2ot5-tT Scadt rls lt2 wPt716t2 026 m Tricolour Progqlict Limhed Not Filed ?or t-r6 Scact m/c I 12 wPt761t2 026 Tri@lour Prcpqrics Lrmitcd Not Filed mrt-7) Search rrls I 1? Pcnaly u/s ftmltyn/s 2?0Apusua{ b riotfrrc n/s lfi datcd oillotm23 Pcoelty u/s 2T0Apuauaat b notiEc u/s ltl8 &rcd zAI2TfrB Perulty r/s 270A pursrnnt !o ftoticc u/s 148 da6d Penaty u/s 271(l)(c) pursmnt!o ootice u/s 148 Feorty u/b 27(!IF) Flr$'trtto ootirc . u/s l{8 dacd Penalty n/s 270Apunum to noticc rr's l48dacd 34 HCJ (ArkS, Jl & GMM, J. W.PJ{o.4O I 18.of 2025 and batch wPntT4l Tri[bur Not Pemltyr/s 27IAAB pursnnt to 'u/s lilt daod wPfix'l 2016 87 Ttirlo.r PtoFdr l-imibd t{ot Iifiml ,fitat1 Sc.rch u/s 132 03-il)-2023 22q9-2023 tErIFir/A wP/lMt 2025 93 Triolo[ :. mt&t? Saardr rrl< tl2 ,R-tr-r$)1 )o-t)-)o)1 wPn167t 2076 91 Trioohr Ptoparica limited Nd Filcd 7figa Scardt ri/s 132 03-r0-2023 2249-2023 ! lJlt.2tr24 $tPfi69t 2025 95 Trido.r Popadr Linid . Not S.ltt .rr/l t12 ztrrlir-l

28.t2-2023 'm-12-202, Eltiltxill wPtrcsa 2026 97 Ttiolorr PtuFdB tini.d Nd ,ftrt-r:, Seatlr u/s 112. wPlt754l 2026 r00 Triaohur Proeqtic Limircd f,Iot Fild xr:t-21 Sc{ch u/s 132 Fcoalty u/s 2?IDA Fr$raot to n/s l4t dacd 03/t02023 Penalty u/s 27IDA pursuant to n/s l{t dated ovrcno2t ataT-ffi, lt{x-1r2s Yes b crT(A ) dismis dE (Oder b cr(A ) dismis 6c (oldcr b w crf(A ) disrnis Ycs (Odc( crt(A ) dismis YCs {o$cr t5 w clT(A ) diEBib .6c Yca (Od.r b p.ssd w crf(A ) dismis Ycs (Ordcr crT(A ) disrnis 6c Ml 35 HCJ (AKrS, Jl & CMM, J W.P.t{o-rOl 18 of 2O25 and batch Seorfty urs 27IDA .Fllglr4t..to rr's tiEd*od Scarch 20t?-18 YES llrXrIP.JrLJl 20tl6-t7 YES n.uxt23 ?9-O3.mi24

27.U.m21 YES lrLtrISIrrll 21fi22023

05.04.2023 o7.uil22

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25.03.2023 Yes t 5.01.2124 YES YES 'Jr,Jruttrl tIf'Illr5 a.ufitI

24.O3.2022 w.u.m222 2r.u.?fi22 Ycs Yes Ycs \ Not t5.t2.2o;24 o5.t2.Nr5 tz.ot.xr24 l\t/-trll ,*I,t!?ltrll Ycs a2.12.21D5 No ,;tlit)ll YES i.rr]rf.tnf,) D.Os.2{)i25 zoiz(t-zt YES

5103.202{ o7J,.3.2024

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21.0/,2022 u.01.202{ wP/I809/ 4()6llr20 23 25 57 6E 69 4no26 76 636t2026 71 6$n026 E5 86 I t9ar202 6 t2Ut202 6 88 t210n02 6 9Z 99 104 to5 106 145tt202 6 t69tn02 6 tEtlno2 6 tE28t202 6 tu4n02. 6 107 t 5t202 6 31 42 wP/40t I wP/4024 2t202s Tridour Sisu Krishna Rm BunEula Raji Rdldw Nasar Bia Salern Bahads R.ami Rcddy Gopired dv- Thc Agriolt Coopcral Crcdil Sociay Mccnav Nmdyal Trading Private l-irnirerl Mr. Molurn Azemu Azam Sri Venkate Rao Tarnmin gI Medikon Bhamni ADECC s Limitcd Jawalur aTgN Educatio Smiav Veru Gopal Eshwaro Siva Rami Reddy c*g Rcddv Srikanth Goud Am Molnrn lbrahirn Ati tJri1iEiitill d lbrahim Ati Not Nor Filcd Not Fitd Not Filed Not Filed Not Filcd Not Filcd Not Filcd Nol Filcd No( Filed IMT Filod Nd Filed Not Filcd Not Filed Nol Filed Nor Filcd Not Filed 36 HCJ (AKrS, Jl & GMM, J W.P.No.to I l8 ot 2025 and bacch [3 59 6t 67 61 71 75 wP/{061 5t20?s wP/t062 ot turs \rPfit53 ?JNs WP/,()6$ onfi2s wP/4O€s tt825 wPt296t2 iin6 WPKT,i2 026 96 u/P/150{/ . 2Ut6 &6ti Scddy &numd. DCS Iimiral l{&ayra i R vtrct . Slfdrr iNd Gtorrdr v Prhori ftfrlfrnr, iStdd .gliii [!liTiEit Kuuar Fr;l UCa .R.oi . iftriliri Pt'rqiutf Agi.ilf ur.l Coop.nt Clcdn . socicty Iinitcd Not Fitd .Filid 10il Fitd Not Fild Not Fi[d t{d FiGd Nd F&d 20t7- 20rt- xI9 an7- 2018 !,t7- 20tt .br7- 201t, !0t.5- lot6 2(}t5- 2016 RMS

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30.03.2024 2E.03.2024 IiTf,B

13.03.202,1 r3.03.2024 2t.06.204r RMS

6.01.2022 05-01.2022 Rtf,B

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02.06.2022

21.07.2022 Itc m No. 9l Casa No. WP/I $tn 026 Ass.s tGt Neuc Sr€d Abdul B.ro Coumer filodor Not Asscs .5illclr i Ycar .. lofo Reccivc d Notii- UA 148 ofthc Act DatG ot Noticc of U/s 148 A(b) of thc IT Act/ Noticc U/s t{8A[) D.tc of Order of U/s l4t A(d) of rhc rr Act/l4E A(3) Dete of Srhctioir U/s t5t Intimetion Urs t,l4 B Ori! of Asst . Order lVheher Asscsscc prcfcrrcd rny eppcel u/s.ar0 of l.T Act . Nr*Filat -. RMS i041-ro2,r )6JJ)-)O)4 10-01-20r{ 1041'-202a fo, {. Ttte, ,2, ,3.

#6. The

#10. //TRUE COPYII ABDI'LI.A+I XINU REGISTRAf, .OF.FICER 110 001,. Tdx Departrnent,'New General of lncome Tax (lnv), lnoorne Tax Dgpartment Finance, lndia, 3rd Floot Jeevan Board of Direct Taxes, Central Secretariat, North ^ - co."\t ___ r00 t1.The Chief Commissioner of lncome Tax, AP and TS, 10th Floor. G Block, l.T ovYers, 10-2-3, A.C. Guards, 'l2.The Principal Commissioner of lncome .Bhawan, Opp. LB Hyderabad -500004 Tax (Central), Hyderabad Stadium, Basheer Bagh, Income Tax Hyderabad Tax Towers, AC Guards, Masab Tank, Commissioner of lncome, Aayakar Bhavan, LB Stadium Road, of lnome Tax (Appeals Hyderabad lncome of lncome Tax, Central Range - 3 Aayakar Bhavan,

500004. Range-13, Hyderabad, lT Totryer, AC this 151 of the lncometax Ac{, 1961) 10-2-3, of lncome Tax, Hyderabad, l.T. Towers, A.C. , Telangana. of lnoome Tax GBlock, zfth Floor, S (Appeals), P M Civic Ce National Faceless ntre, New Delhi - 1'l Appeal 0001.

#13. The

#14. The

#15. The Joint

#16. The Joint Masab 17.The Chief Guards,

#18. The Centre

#23. The Assistant Commissioner of lncome Tax, Central Circle-3(4), H$erabad Aaykar Bhawan, Opp. LB Stadium, Basheer Bagh, Hyderabad, Telangana- 500004.

#24. The Office of the Assistant Commissioner of lncome Tax, Central Circle-2(3),

#25. The Asst. lncome Tax Hyderabad. of lncome Tax, Circle-I Office, Aay, kar Bhawan, Opposite LB Stadium, 500004 ), Hyderabad, lncome Tax 2(1 Basheer Bagh, Hyderabad

#26. The Office, Deo Office Road, Tax Officer,

#27. Ttlc Incorne LB Stadium, 28.The lnome Tax lnoome Tax Officer, Ward-l, Mahabubnagar lncome Tax 1 H -1 1, n, Opposite 6-2-156/3,

#35. Tank, Hyderabad, Telangana 1 re Towers, ical Gardens. , Ac Guards, Masab l0l

#36. The lnorne Tax Officer Ward-1, Warangal, lncome Tax Offie, D. No. 1-8- - -= 610: 3rd. Floor, Mayuri Complex, OPP. TSNPDCL Bhawan, Nakkalagutta Hanamkonda, Wa I T Tower, Ac qJards, 37.The lncome Tax W

#1. 14(1 MaSab Tank, Hyderabad, Telangana, 38,The lnoome Tax Officer, Ward 1, SiddipeU lncome Tax Office; 8-1-22, 1sl Floor, Subhash Road, Siddipet, 39.The lncorne Tax Officer, Wa bad - Guards, Masab Tank, Hydera 40.The lncome Tax Officer, Ward Kondapur, Sy.37(P) (M), R.R.District, Hyd Tax Officer, Ward No.6(F) of

#41. The nCC'me 1 -502103 Hyderabad, 10-2-3, l.T.Towers, AC 004, 17(1 na. Towers, Gardens, Sy.No.6(F') of Kondapur, Sy.37 Sedingampally (M ), R.R.District, Officer, Ward-(l PCIT 1, Signature'Towers, Sy No 6(P), 42.The lncome Tax )of 1), Hyderabad/ ignature Towers, Bdanical' Gardens,

#44. Near Rail TTOWER, AC Guards, Masab Tank, HYDERABAD, 500004 4S,lncome Tax Officer, lncome Tax Office, Circle 1(1), Hyderabad, lT TOWER, AC Guards, Masab Tank, HYDERABAD, 500004. Guards, Masab Tank, Hyderabad - 500 004. 47.The lncorne Tax Officer, lncome Tax Office ,t6.The Office of the lncome Tax Officer, Wad 6(1); Hyderabad lT'Touers, AC ), Hyderabad, I T 48.The lnconre Tax Officer, Ward 1a(1), Hyderabad, lT Towes, AC Guards, TOWER, r\C Guards, Masab Tank, H Masab Tank, Hyderabad - 500 004, Telangana.

#49. The lncome Tax Officer, Ward-1, Kothagudem 6-12-38, Ganesh temple Main

#50. 51. 52. 53. 54.

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#7. DISPOSING OF ALL THE WRIT PETITIONS, WITHOUT COSTS s(q. dgl2o?a'