The High Court · 2025

Ileard Mr.A.V.A.Siva Kartikci il. iearricr,l counseI fbr the petitioner and Ms. B.Sapna Reriti.,., lcl,r.ncd Senior Standing Counsel for the Income Tar: I):paltnent a1.)pcar.ing for the respondents. Perused the rccord. 2 This is a writ petition r.r,here rr,-e ptoceedirrgs are either challenged to the notices wtrich *,erc issued rrrid:. Section t48A and l4E of thr: Income Tax Act, i9C, t ({or short 'tho Act') or the assessment orders those have been ltassed r.indel. Scc:ion 147 of the Act which have been assailed,

3. This writ petition is being tiriruri tip krtja," oniv oir one of the grounds, that ttre notices issue<l unr.l;t. Settion i.l8A of thc Act and the subsequent initiation olproc11,ji6g5 unricr Section 148 of the Act by the jurisdictional Asscssii.r.!,-- i.)flicr:r. vr.irereas in terms of the amendment that was brough'L trr the Inc,,rrne l'ax_ Act by way of Finance Act, 2O2i w.e.f., 0i {1,1.':,121 on'*arri:;, proceedings 2 under Section I48A of thc Act as also under Section 148 of the Act ought to have also l-:e.'n issued and proceeded in a laceless manller

1. Thc cortientiot't t.rf ih'.- petitioner is that the issue of procccclings being in violation ol the Finance Act,202l i.e', the impugnecl notices Lrn(ier Sectiitu l48A and Section I 48 of the Act not being issued in a laceless lllantler, have already been dealt with and decided b;' this Clor.rrt in the case of KANKANALA RAVINDRA REDDY vs. INCOME-TAX OFFICERT decided on I 4.09.2013 wlrcre by a L-'aich o1' r+'rit petitions were allowed and the proceeclings initiated uncier: Section l48A as also under Section 148 olthe ,A.ct q,e|e held to be bad with consequential reliefs on the ground oi- it being in violation of the provisions of Section 151A of the Act tead r'vith Notification 1812022 dated 29.03.2022. The said iudgment passerl by this Corrrt has also been subsequently followed in a large trumber of wr-il. pr:titions which were allowed on similar terms. '[(2023) 156 taxnratttt.conr 1?,q ( l clangana)l

5. Down the line, we find that the sanie issue has also been decided against the Revenue b,v verious High Courts i.e., by the Bombay High Courl iri tl-,e case of HEXAWARE TECHNOLOGIES LTD., vs. r\SSiS'IANT COMNIISSIONER OF INCOME TAX & OTHERS:, iieirhati IIigh Court in rhe case of RAM NARAYAN SAH vs. tiNlON OF INDIAT, Punjab and Haryana High Court in the case of JATINDER SINGH BANGU vs. UNION OF INDIAI, and Telanil"in:r Fiigh Llrurl in the case of SRMN KATARAMANA' REDIIY PATLOOLA vs. DEPUTY COMMISSIONER OF INCOMFI 'l'.1\s uhcrc rhe issue was in respect of international taxation. B,.l:rrb:y li igir CoLirt in tl're case of ABHIN ANILKUMAR SHAII vs. INC,O]ITE TAX OFFICER, INTE,RNATIONAL TAXATION" q.iiich is agzrin on inrernarional taxation and central circle, High Ci-.rirt trf l{irnachrrl Pradesh in the case of GOVIND SINGH vs. INCON,IE TAX OFFICERT, Gu-iarat High Court in the ..rii-ic ol I\.IANSUKHBHAI ' ;zoz+1464 ITR 430 (Bom) '[(2024) 156 taxmann.com 4T8 (GauhaLi)1 " [(2021) 165 taxmann.com ll5 (Puiii.r]: Jr ilaryana)l '[2024) [67 taxmann.ootn 4l I ('felang,r'ra;l " 12024) 166 taxmann.cofr b79 (Bornba , rl 'L2024) 165 [axmann.corn I l3 (Hirrar:hal i'r:rdesh)l 4 DAHYABIIAI tIADADIYA. r's' TNCOME TAX OFFICER' WARD 3(-1X5)*. Jharliancl liigh Court in the case of SHYAM SUNDAR SA\\.rs. IINION Oli INDIAe, Raiasthan High Court in the case ol SHAIIDA DF.VI CHHAJER vs. INCOME TAX OFFICER & ANOTHER. aod batch of writ petitionsr0 which stood decicied on 19.0i.2024 Sir.nilar views have also been taken by the Divisiorr lJcnch ol (]alcutta High Court in the case of GIRDHAR (lOPAl, DALM,A vs' UNION OF INDIA & ORS (M.A.l- 1690 cri i(i23). d,:r:iri.:ri ort25.09.2024.

6. t.ven tl-roLtsi: lhr sairl,r il.,ue having been decided by a large number of lJigh (.c,rrrr.s, *c ;-r1u 5t!![ confronted with large filing of identical urai!,crs on daiii' basis ranging between 5 to 10 writ petitions. Thiit .rpou thc r l-rs iL't-lctions being sought from the Department. thcr havc trec'ir iaking a solitary ground that the decision of ihc ilomba-r Ilitrh (lourt in the case of Hexawure Technologies l-r(t". ()- sirpr.:i rs also the one which has been decided b1 ti.ris ('orrr-t it.t titi .r:rsc ol Kanaksla Ravindra Reddy 8202+ SCC Onl.int (ir;.i 4(J l2 '2025 SCC Orl-irrc.lhar l87 'n12023, RJ-.lr):-loE.l.r)tl ! J (l supra) has been subjected to chailcnge in a Special Leave Pctition i.e., SLP No.3574 of 2024 lretbr.e the iion'ble Supreme Court and the lJon'ble Suprerne Court is scizcd of the matter In addition, there are about 1200 SLPs also tilecl aiising out of the same issue being decided by various I ligh Courrs

7. To a query being put to the learneC counsel tbr. the Revenue, they have categorically accepted tl-re l-act that there is no interim order granted by the Hon'ble Snprenre Court in any of these matters pend ing before it. N,lean,,vhile, lresh writ petitions of identical nature are being piled up bcfore this Bench on daily basis and the pendency is getting increase<i orl nlatter r.vhich otherwise has already been dealt and decided hr thl5 1,gry I{igh Court itself.

8. On the one hand, even though the or.der. of this Courl that was passed as early as on 14.09.2023 and more 16 months have lapsed, till date, we do not find an5, ierredial stcps having been taken by the Income 'lax Departmenr to take appropriate steps to either hold back issuance of notice undei Section l4!iA and under Section 148 of the Act by the jurisdictional Assessing Officer, rather the authoritics concemed in rhr. teeth of series of decisions 6 by att the ma!or I ligh (-,:rrttts in lndia are continuously still initiating plocceclings unclcl Scction l48A of the Act and also initiating plocecdiirgs tttrilt:i' Section 148 of the Act in contravention to the atucrldnri:nts brought into the Income Tax Act pursuant to thc r iniince Act. l()20 as also the Finance Act 2021 ' g. Upon a cli.ter',. be inr 1':ri: ii: to u'hy can't this writ petition be disposed ol- in rhc teeth ol'rire dccision rendered by this Court in the case of Kanakulo Rurintlrt Rcddy (l supra), learned Standing Counsel fot the inc,lrrc. ir'1 i.r1'r11[;11ent cot]tends that those would urLnecessariil, bLrtclcn thc i;;i-r-rllle Tax Department where they would be recluitcci ro flit crllr;ri tlumber of S['Ps before the Hon'ble Suprctn,: L-oittt alrrl ;', rvould be t'urther burdening the exchequer of thr: i--li-:ioil ll itrrir':. It was also the contention of the leamed Standing Counsci ti!r i .() prejudice would be caused to the interest of the pctitio;rcrs ilr L' :i. ii this wlit petition is kept pending till the finalizaliorr oi t'ns l,l.trs pending before the Hon'ble Supreme Coun antj thc iact l';ri the petitioner is already enjoying the benefit ol irtcrrrr prolCCl ii')n. Nonetheless, on the earlier query of this Court as io ,.rhy [he intotnc Tax Department have not come out with a r-n:cir,l'lis:n t(r i. .,.,.' ,rilpropriate instructions or to take 7 appropriate steps in ensuring that lrr.oceedirrgs under Section I48A of the Act as also the assessment olders urrder Section 148 of the Act are kept in a hold in the tight oi tlre decisiorrs dedcided by the various I ligh Courts, it was sub;;ritted by the learned Standing Counsel that the said steps can only bc ttrkerr at the level of CBDT as any such steps would have to be raken Pan lndia and cannot be limited to any of these jurisdictional Fiigh Couits.

10. As a result of which, what \ve alr: thcing is steep increase of litigation day in and day out even though various orders have been passed by this High Court allor.r,ing 'urlit petitions on the very same ISSUC Thc [ncorne fax authorities cr-rncerned are still even now in 2025 also initiating proceedings in coctravention to the provisions of Section I5l A ol the Act and as a rcsult by now, more than 600 to 700 petitions have been already got piled up betbre this High Court on an issue which otherwisc stands squarely covered by the judgment ot'this Court in the casc o{ Ksnukula llavindra Reddy ( I supra). What is also surprisine is ihe fact that though while allowing the writ petitions in the case ol Kanaksl{t Ravindra Reddv (l supra), the Division Bench .,vhile reserving the right of the Revenue, has also protectcd tlic interest of the petitioners |1 insofar as the libcity rrltlcr ....'.ts granted to the Revenue for initiating fi'esh 1-.roctedings si.icli' in accordance with the amended provisions of the r\ct, as atitetrilcd by the Finance Act, 2020 and the Finance Act. 201 i . J hr.: ne iiLit.,rter assessee would be entitled to challenge or raise thc c'tirer l.-1lai objcctions if the Revenue initiates fresh proceedings. 1-he l)cpartnrcnt has rnade no endeavour in availing the saict liberty thal r" iis resewed fbr the Revenue. On the contrary, they have been sliii sticking on to the stand, which this High Court as weli as rnan; oilicr l-ligh Couns already held to be bad.

11. lt appears lhat bcr:aL:s.' ,,1'ilre albresaid tiberty that this High Court had granted periniriir,. ihc Rc',enue lor initiating fresh proceedings as a one-tirt.:u ilJ.ilure in a face[ess manner, the Income Tax Depar'lrnen!- i\'arlis to take advantage of the same by protracting these procccdiiir..s '.1irich rvoulci enable them to meet the limitation that rvouid other'ri r.;.: cotne in the way. Likewise, if the writ petition is kept pcnriiril: iiri :t considerable long period of time and hnally at a latel stage ii iirt I lon'ble Suprerne Court confirms the decision taken by this l li,rh (loufi as also by the other High Courts in which rhe SI-Ps ,r: c still lrending, the Income Tax 9 Department would get the advantage ol.the liberty that is otherwise protected in fhvour of the Rer.cnue lor initiation of fresh proceedings liom thc disposal ol these r atters at a nluch later stage which would be advantageous anC beneficial to the Revenue and would be equally disadr,.antageous:utci rlctl.irnental so I'ar as interest of the assesses are concerned. A-. ir_ coilsequetce, lhe Income Tax Department gets an extended perioc of time tbr initiation of fresh proceedings.

12. The alarming trend of docket exp.rl6si6n in this Court, despite the clear precedent set in KunuA.tltt littrinrlra Reddy (.l supra), is a matter of grave concem. 'fhe Incorue l'ax l)epartment's persistent initiation of tiesh proceedings, disr.egarding the established judicial pronouncements, has lcd to an ullprccedcnted surge in litigation with over 600-700 petitions pi lirg up on the same issue. This deliberate approach not only underr:rines the principte of judicial precedent but also strains the jurllciai :.esourccs unnecessarily. The Department's strategy o['awaiting iit,-. Sirprenre Court's decision on pending SLPs while continuing r,-: iiritiate fresh proceedings appears to be a calcrrlated moyc l,r buli time and circumvent limitation periods, raiher than ad jr,riing tit the established legat 10 position. Such conduct llrises serious questions about the administrative ef{iciency :tttd the respect lbr judicial pronouncelnents, pratticr.riarll rvhen this Court has already provided a balanced apploach by prescruing both the Revcnue's rights and assesses interests-

13. Another aspect which necds I-o be considered is that in fact it should have been realized bi' iht [,rcotne 'l'ax Dcparltnent itself and should har.'e loiind out vi:,: ir,,.rdia in ensuiit.tg that proceedings under Sections 148-r\ anri l'lr strotrld not have been issued in a faceless mirnncr'- at least t!li rl.,.r ilrrn'ble S,.tprctne Court decide the twelve hundled (1100) cdil Si |'; ''vhich it is alreadl'seized of or, at least the Incotne Tax l)cparlirent should have fbund out some remedial steps ',o enstlrc ihiii- ',vherevcr the authorities intend to initiate proceedings under Sei:iions 148-A and [48. other than in a faceless manner, Lhc irrocetdings should havc been deferred without precipitating thc ntirl-tcr l'urlher intimatir"rg the assessee that they shall initiate appropriali: il'oceedings only after the S[,P's are decided by the tton'ble Sitpl',:tne Coult on the very same issue. This again, the incr:rne -fax !)':irartrnent, has not been able to give a convincing reply. erlcpt tb: lhc l-act tlrat such a decision if at all t1 has to be taken, has to be takcn tbr LIte rvhole of lndia, and which otherwise has to be by rvay of'a policl, decision and lhat too at the level of Central Board ol Direct I'ttxes. 'l'hough the learned Standing Counsel fbr the lncornt lli.r l)eparrrnent contended that the Delhi High Cour-t dismissed a ',r ril 1:etirion of -similar nature, on the one hand when the I{igh ('rrLriL is stluggling to reduce its pendency, such notices rvhich ar.:: Lutdr_-r challengc in this writ petition are fbrcing Lhc assessce t.r i.-r:rrck the doors ol this High Courl resulting in lrling of hundrcd. of.rrew u,rir lrctitions which in the long run not only affects tlrc <ii:ir,.,r;ai of tjrc. i.vr.it petitions but also consumes substar-rtial time of' ,-hc Bcnch in hearing these matters again and again on dailv basis. A{imittedly, in spite of the matter before the Hon'ble SuJ.1'31-,1g ('or-rrt having bcen taken on many occasions, the Hon'ble Suprtrrre Corirt which is seized of the matter has been reluctant in grantii ri,. an1, iittcrim protection to the Income Tax Department. Yet. tlre .t,_ilhoritics concemed at the State level are not ready to accept thi. r,erclict passecl by a majority of High Courts of different Statcs on thc sar-ne issue; and to make things further worsc, the Incorn.. l'i;.,1 Deltartment is showing audacity by issuing noliccs contir.ruoirsiy uirder Sections l4g-A and "12 148 through the.!ulisdictiolr.it ,'\ssessing Offlcer rvhcreas it ought to have been onlf in the laceless flanner

14. In the case o1' t],'\NK OF INDIA vs' ASSISTANT COMMISSIONER' INCOIvIE T,A,Xr', on nt.' issue whether it was justifiable on the palt of the lncome Tax Department in not foltowing an orrier passed blr tirc adjuciicating authority only on the ground that thc appcats arc pcnding' the Division Rench of the High Court of Bornbay held at paraglaph No.25 as under, viz , : "25- t\.4r. Par;d\r''alla h;:s rrghtly drawn out attentlon to the decision cf this Couri in Commissioner of lncome Tax vs' Smt' Godavaridevi Saraf'2 as also the recent decision of the co- ordinate Bench of this Court in Samp Furniture (P) Ltd' v' lTOr3 of which one of us (.juslice G.S Kulkarni) was a rnember, wherein the Court categorically cbserr,,'1cj that the Revenue having not "accepted" ttre judgrnent of the Higlr Court would not mean that till the same is set aside in a iaanner known to !aw, it would loose lts binding force. Referring to tire decision of the Supreme Court in Union of India vs. Kamlaksh! Finance Corporation Ltd'14, the Court observed that the approach of the officials of Revenue of treating decisions being "nct ac.eptable" was criticized by the Supreme Court. ln such tje;ision, following are the relevant observations made by the Suirreme Court " 11zozs1 I70 ta\rnann.com 412 (l']ombay)] 't Jtsz8l I i3 I'ft( 589 (Bombal) '3 IZOZ+1165 taxr:rann.ootr ,581r'-100 " 1t9921 ta\manir.corn i5i55 i i I 4-i3 (SC) 'laxtnan 452 (Bombay)

1.) "6. Sri Reddy is perhaps :-igrr rn saying tnat the officers were not actuated ay any male frdes in passing the impugned C|.ier=.. They perhaps genuinely felt that the clairn cf ille assessee was not tenable and that, if it was .1i:,:eDieC. ihe Revenue would suffer. But what Sri Rei:,1y cvertocks is that we are not concerned here v,,ith ll.,)e co.rectness or otherwise of their conclusjor-r oi of any factual malafides but with the fact lhai lire cfficers jn reaching in their conclusion, by-passe(l i.wc appellaie orders in regard to the same issue u,/l.ltch were placed before them, one of the Collector (Appeals) and the cther of the Tribunal. The High Coui has in our vrew, righfly criticized this conduct of the.^\sststant CDllsctc,rs and the harassment lo the assessee caused by the failure of these officers ,to give efi-c.t to the orders of authorities higher to them in the api_.eliate hjeraichy. lt cannot be too vehementiy emphasrzecj that rt ts of utmost importance that, in .jisposing of the quasijudicial issues before thern, revenue offrcers are bound by the decisions of the appeiiate authorities. The order of the Appellte Cotiector ls btrjding on the Assistant Collectors working wiihirr his jurisdi.jtron and the order of the Tribunal is bino,t-lg upcn ihe Asststanl Collectors and the Appellate ,_ ciiectors :,vito fjr)ctton under the jurisdiction of the -l libunal. t-he princrpies of judicial discipline require thai tire orders of the higher appellate authoritles should be folicv/ed unreservedly by the subordinate authoritiee. Ihe mere fact that the order of the appellate authc[ty ls nct ,acceptable,, the department - in itself an objectionaltle phrase _ and is the subject matter of an appeai can furnish no ground for not following it unless its operatlon has been susperded by a competenr court lf this healthy J L4 !-ule is not followed, th? result will only be undue harassment to assesses and chaos in administration of tax laws. 12 We have dealt u/itl- this aspect at some length, because it has been suggested by the learned Additional Solicitor General that the observations made by the High Court, have been harsh on the officers. lt is clear that the observations of the High Court, seerningly rrehement. and apparently unpalatable to lhe Rev-ooue, are only intended to curb a tenclency in revenue matters which. if allowed to become widespread, could result in considerable harassment tc the assessas-public without any benefit to the Re,/enue. ..ir!i.. would like to say that the departrnent should take these observations in the proper spirit. l-he observations of the High Court should be kept in mind in future and the utmost regard should be paid by the adjudicating authorities and the appellate authorities io the requirements of judicial discipline and the neeci for giving effect to the orders of tlre lrigher appellate authorities which are binding on therli." I 5. \\/hat is ,.vorrying ihi:; Br:nch more is the fhct that an endeavour is being made whcle hearledly to ensure not to generate further litigation on issues rvhich have been laid to rest by a large number of I{igh Courts ail ot u{tom have taken a consistent stand that the action of the lncon-rc'l'ax Department being violative olthe 15 Finance AcL,2020 and Finance Acr, ,:01l. Now, ln older to protect the interest of the Revenue as also tirai o1' the asscssee. it would be trite at this juncture, if rve dispo:;e oi' tire '"r rit irctition with an observation/direction that the disposai o1'the instarit rrrit petition in terms of the judgn-rent rendered b;,, thi:r I {i1rh t'o'rrir- in the case of Kankonola Ravindra Reddy (l sulrr;r) shall lrovvevcr be subject to the outcome of the Sl-Ps which r.r, ere lilcd b1, the lncome 'lax Department and which is pending cLiiti iiicratiolt beiiri'c t.he [{on'ble Supreme Court.

16. In the given facts and cil curr stlrflces. this Rtnch is of the considered opinion that unless anci irrrlii we clo noi Lr;,.rely dispose of matters which are squarely cor.ered b,v the decision ol this Court and which stands fortified by the Ceci:;ions ol'tirc various other High Courts on the very same issr,:. iirc I'rcurie'ncy ol this High Court would further be burdened rvi:irii otliolrvisr c:in be decided and disposed of as a covered matl.ei 17 . So far as the interest of the Rei.,.'rruc is concerned, we are of the considered opinion that the interest of itre Re., cnue has already been considered and protected, as ha.., hcr:n obsrn,etl in paragraphs 1b 36, 37 and ,i8 oi the ot-del i'iiricl-,, tbr ready relerence, is reproduced hereuuder 36 Frr ali ihe afcresatC reasons, the lmpugned notices issued and the proceeCings drawn by the respondent- Depadnrent is !-!eithe!' tenable, nor sustainable. The nct,ces so issucil a!':C lhe procedure adopted being per se rliegal, deserr,es tc be and are accordingly set aside/quashed. As -a consequence, all the impugned orders Eettrng quasi.)e,i, the oonsequential orders passed by the J eslir)rident-u"oailment pursuant to the notices lssued urider Sect;!',n 147 and 148 would also get quashe<i and rt is orrrtred accordingly. The reason we ai'e quashrng the conseqireittial order is on the principles tnat when ihe' ir'rrti3ticI of the proceedings itself was proced,.irailv i,uronil, tlie subsequent olders also gets nulhfiecl automaticaiii, 're pre!iminai-i; ci',,;aclion raised by the petitioner is 37 sustaired and aii trese writ petitions stands allowed on t\is ve!"',' jrrrsdicticnal Issue Since the impugned notices and or-iiei-s are ge'r1ing quashed on the point of I'ri-rsdiclron. '*" rra ;,r.,i :nclirled tc proc-oed further and decide the oihei issrcs raised by the petitioner which stands reserueC lc :'l raised and contended in an appropriate [)roceec]r Ir:1s 38 Sirrce the Ficn bie Supreme Court had, in the case of Ashish Agaruval, supra as a ottetime measure exercising the polrers under Article 142 of the Constltlltion of inoia. ;:ermitted the Revenue to proceed under the substitute.J p:ovisions, and this Court allowing the petitions only on the procedural flaw, the right 77 conferred on the Revenue \,/o,-tld remain reserved to proceed further if they so walt ft'om the stage of the order of the Supreme Coirrt ,n the case cf Ashish Aganr'ual, supra.

18. We would only fufther like io rnake obsen,;rtions that since we are inclined to dispose ol the i;'rs;i:rrt u.iit pctition. cotlscious of the fact that the earlier order of this tliiih Coi-rrt iu the case of Konokala Ravindru Rerl/y ( I sup;"a) IS subjccted to challenge before the Hon'ble Supreme Couri in SLP No.35 7-t oI- 2024, prefemed by the Inconre Tax Depait;nelt, we lnakc it clear that allowing of the instant writ petition is sutrjeci tc outcome of the aforesaid SLP prefen'ed by the }ler':r,re against thL-- decision of this High Court in the case of Kanaktlc lluvindru /{crld1, ( i supra) '[his, in other words, would mean thil either ci the partics, il' they so want, may move an appropriatc f,e titi.ln sccking lc.r'ival of this writ petition in the tight of the decision of the I lon'blc Suprerne Court in the pending SLP on the Ie n sliLle iss;u,,-.

19. Accordingly, the instanl rvlit petition stands allowed in f'avour of the assessee so far as ttre issue ol' iut isdiction IS concemed. As a consequence. tir,: impr rgneii r-rotice under challenge under Sections 148-A and i,i[i stands set aside/quashed. 1d The consequerrtiai orde r''s. !i .rri','. aiso stand set aside/quashed in similar tenns as ltave beerr l,.r:.s.'ci by this High Court in the case of Kankanola Ruvinlra Rcd::i.t i i .'r-ioro). 'I'here shall be no order as to costs Consequentlv. nriscelialgous petitions pending, if any, shall stand closecl //TRUE COPY// SD/-T. JAYASREE PUTY REGISTRAR SECTION OFFICER o 1), Hvderabad, LT 1. The Assistant Com missioner of lncome Tax, Circ - 500 044, Telangana Towers. 10-2-3, AC Guards, tvlasab Tank, HYdera 2. The PrinciPal Chief Commissioner of lncome Tax, Telangana, HY derabad. Room No. 922. 9th Floor' BB lock lT Towers' 10-2- 3. A.C. Guards, Masab Tar1k, HYderabad - 500 004, Telangana 3. Assessment Unit, lncom e Tax Department,, National e-Assessmen t Center. New Delhi, Room No.- 401, 2nd Floor' E-Ra mp, Jawaharlal Nehru Stadium. New Delhi - .1 '10 003. &;;;'i; st, n V n siva Kartikeva Advocate.[oPucl one cc to tvls Bokaro srpJH;i;'vJsltitiSd lhcome rax) toPUCl Two CD CoPies ndhra Pradesh and 4 5 t) To, TJ BS HIGH COURT DATED:191OG12025 ORDER WP.No.16900 of 2025 siA). s ($ ,.) .J lJE 26 H2 * r)5 sI)4TC '..rf,O ALLOWIG THE WRIT PETITION WITHOUT COSTS s \\x