Courts i.e., by rhe Borlbay High Courl in the case of HEXAWARE TECHNOLOGIES LTD v. ASSISTANT COMMISSIONER OF INCOME TAX OTIIERS

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 or direction or order more particularly in the nature of a writ of certiorari cafling for the records and quashing the (i) rmpugned order BbearingDlNS6NoticeNo,ITBA/AST/Ft14}At2o25-2611o77291451(1)fortheAY 2o1g-2o2o,dated20.06.2025issuedbytheRespondentNo.3underSection 14BA(3) of the lncome Tax Act' 1961' and (ii) lmpugned Notice Cbearing DIN and, Notice No. ITBA/AST l}ll48 112025-2611077294502(1)dated 20'06 2025 rssued by the Respondent No 3 under Section 14g of the rncome Tax Act, 1961 as being i'egar and in vioration of appricabre raw, and consequen,y set_aside a, conseq uenUsu bseq uent notices/o rde rs/penalties and further restrain the Respondents from making any assessment, reassessment or re-computation or otherwise proceeriing against the petitroner on the basis of the aforementroned lmpugned Order B and lmpugned Notrce C Notice dated 20.06.2025. IA NO: 20 F 2025 petition under section 151 cpc praying that in the crrcumstances stated in the affidavit fired n support of the petition, the High court may be preased to suspend a' further proceedings pursuant to(i) rmpugned order bearing DrN and Notice No. ,TBA,/AST/F/ 14BA/2O25- 26t 1O772g14Sr1r; ,o,. ,r; ;;;;;; dated 20.06.2025 issued by Respondent No. 3 under Section i48,4(3) of the lncome Tax Act, i 961, and (ii) lmpugned Notice bearing DIN and Notice No. ,rBA/AST/S/ 148 112025- 261 1077294502(1) dated 20-06.2025 issued by the Respondent No 3 under section 14g of the rncome Tax Act, lg6.rincruding a, consequenu subsequent notices/orders/pena rties, in the interest ofjustice. IA NO: 30 F 2025 ;, Petition unde' section 151 cpc praying that in the circumstances stated in the affidavit fired in support of the petitron, the High court may be preased to stay the operation of (i) lmpugned Order bearing DtN and Notice No. rrBArASTrFrl4BAr2ct25-26r10772g1451(1) for the Ay 201s - 2020, daled 20 06'2025 issued by the Respondent No. 3under section 1484(3) of the rncome Tax Act, 1961, and (ii) Impugned Notice bearing DIN and Notice No. lrBA/AST/s/ 148 1/2025-261 1o772g4so2(1 ) dated 20.06.2025 issued by the RespondentNo. 3 under Section 148 of the lncome Tax Act, -196.1 including all consequenV subsequent notices/c rd ers/pena lties, in the interest of justice. lA NO: 1 OF 2025 Petition under section 151 cpc praying that in the circumstances stated in the affidavit fired in support of the petition, the High court may be preased to dispense with- the firirg of certified copy of (i) rmpugned order B bearing DrN and 'nO Notice No. ITBA/AST/F/'14 BAI2O25- 2611077291451(1) for the AY 2019 - 2020' dated 20.06.2025 issued by the Respondent No. 3 under section 148A(3) of the ("' lmpugned Notice C bearing DIN and Notice No' lncome Tax Act, 1961' ITBA/AST/S/14 8-112025- 2611077294502(1 )dated 20-06'2025 issued by the Respondent No 3 under Section '1 48 of the lncome Tax Act' 1961 ' Counsel for the Petitioner : SRI SHEETAL SRIKANTH counser for the Respondent No'1 Counsel for the Respondents No'2to4: Ms'B'SAPNA REDDY' Jr'SC for lT DEPT The Court made the following: ORDER ' 3T:rA?:E[lXit-* KUMAR' I t ! i I I i i i i i l THE HONOURABLE SRIJUSTICE P.SAM KOSHY 'rHE rroNouRABLE T$r}'rarr"" NARSTNG RAo NANDIKONDA WRIT PETI TTON of 2025 OITDER (,c e r Ilo n, b / e .l r i Jus t i c e .\r ar s i ng ll uo Na nt! i ko n du) 18707 No. Heard Mr. Sheetal Srikanth, learned counsel for petitioner rrncl Ms.B.Sapna Reddy, learned Senior Standing Cor-rnse[ fbr the Income Tax Deparlment apoearing for the respondents, per.used the record. 2 This is a writ petition rvhere the proceedings are either chalienged to fhe notices which were issued under Section l4BA and I48 ol the [ncome Tax Acr, 196l (for shod ,the Act,) or the :lssessment orders those have been passcd under Section 147 of the Act which have been assailed.

3. This rvr.it petition is being taken up today onlv on one of the grounds, that the notices issued under Section i4gA of the Act and the subsecuent initiation ofproceedings uncler. Section l4g of the Act by the jurisdictional Assessing officer, wrrereas in terms of the amendment that was brought to the Income Tax Act by way of Finance Act, 2021 rv.e.f., 01.04.2021 onwards, proceedings

2. under Section 148,{ of the Act as also under Section 148 of the Act ought to have also been issued and procecded in a faceless manner'

4. The contention of the petitioner is that the issue of proceedings being in violation of the Finance Act' 2021 i'e'' tl.re impugned notices under Section 148A and Section 148 of the Act not being issued in a faceless manner' have already been dealt with and decided by this Court in the case of KANKANALA RAVINDRA REDDY vs' INCOME-TAX OFFICERT decided on 14.09.2023 whereby a batch of writ petitions were allowed and the proceedings initiated under Section 148A as also under Section 148 of the Act were held to be bad with consequential reliefs on the ground of it being in violation of the provisions of Section 151A of the Act read with Notification l8l2l22 dated 29'03'2022' The said judgment passed by this Court has also been subscquently follorved in a large number of writ petitions which were allowed on similar terms. ' l(2023) 156 taxmann.com 178 (Telangana) l 5 Dou,n the line, we find that the same rssue has also been decided zrgainst the Revenue bv vafious Fligh Courts i.e., by rhe Borlbay High Courl in the case of HEXAWARE TECHNOLOGIES LTD., vs. ASSISTANT COMMISSIONER OF INCOME TAX & OTIIERS2, Gauhati High Court in rhe case of RAM NARAYAN SAH vs. UNION OF INDIA3, punjab and llalvana IIi-eh Court in the case of JATINDER SINGH BANGU vs. UNION OF INDIAI, and Telangana Fligh CoLrrt in the case of SRI VENK{TARAMANA REDDY PATLOOLA vs. DEPUTY COMMISSIONER OF INCOME TAX5 where the issue was in respect of international taxation, Botnbay l{igh Court in the case of ABHIN ANTLKUMAR SIIAH vs. INCOME TAX OFFICER, INTEITNATIONAL TAXATION6 which is again on inrcrnarional taxa[ion and (]entral circle, F{igfi Court of Himachal pradesh in the INCOME TAX OFFICER?, CASC of GOVIND SINGH (iujarat High Court in the case of MANSUKHBHAI t lzoz+1464 I ll( 4J0 (Born) J( 2U24 ) I56,a):rnirnn.corn 47g lCauhati)l '1Q024) 165 lar:rnann.com I l5 (punjab & Haryanr 'l{011r 167 rrrrrnann.com 4l I (Tela;gana)l '[2Q24) 166 [axmann.corn 679 (Bombay)] ' [2021) 165 rirxrnann.com f f : iff imacfai pradesh)] 4 DAHYABHAI RADADIYA VS. INCOME TAX OFF'ICER' WARD 3(3XOE, Jharkand High Court in the case of SHYAM SUNDAR SAW vs' UNION OF INDtAe' Rajasthan High Coun in the case of SHARDA DEVI CHHAJER vs' INCOME TAX OFFICER & ANOTHER and batch of writ petitionsro which stood decided ot 19 '03 '2024' Similar views have also been taken by the Division Bench ol Calcutta High Court in the case ol GIRDHAR GOPAL DALMIA vs' UNION OF INDIA & ORS (M.A.T 1690 of 2023)' decidcd on25'09'2024'

6. Even though the same issue having been decided by a large number of High Courts'' we are still confrontcd with large filing of identical matters on daily basis ranging between 5 to 10 writ petitions. That upon the instructions being sought from the Depaftment,, they have becn taking a solitary ground that the decision of the Bombay Iligh Courl in the case ol Hexaware Technologies Ltd', (2 supra) as also the one which has been decidM by this Court in the case of Kanakala Ravindra Reddy \ 82024 SCC Online Guj 4012 '2025 SCC Online lhat 281 'o 7zoz3, RI-JD :49 84-DB l J (l supra) has been subjected to challenge in a Special Leave Petition i.e., SLp No 3574 of 2024 before the Hon,bte Supreme Court and rhe Hon,bte Supreme Court is seized of the matter. In addition, there are about 1200 SLps also filed ar.ising out o1. the sanre issu,., l.eirrg decided by various High Courrs. 7. To a <1uery being put to the learned counsel for the Revenue, tl'rey havq crttegorically accepted the fact that therc is no interim order granted by the Hon,ble Supreme Courl in any of these matters pcnding befbre it. Meanwhile, fresh rvrit petitions ol idenricaI nature are being piled up before this Bench on daily basis and the pendency is getting increased on matter which otherwise has ah'eady bi:en dealt and decided by this very High Court ilselL 8. On the one hand, even though the order ot.this Court that r'r"as passed as carly as on 14.09.2023 and more I 6 rnonths have lapsed, till date. we do not find any remedial steps having been taken by the Iocome Tax Department to take appropr.iate steps. to eithel hold back issuance of notice under Section l4gA and under Section 148 ol the Act by the jurisdictional Assessing Officer, rathcr the authorities concerned in the teeth of series of decisions '.J. 6 Tax Act by all the major High Couds in India are continuousiY still initiating proceedings under Section 148,4 of the Act and also initiating proceedings under Section 148 of the Act ln contravention to the amendments brought into the lncome pursuant to the Finance Acl' 2020 as also thc Finance Act 2Q2l ' g. Upon a query being put as to why can't this writ petition be disposed of in the teeth of the decision rendered by this Court in the case of Kanakala Ravindru Retttly (l sr-rpra)' learncd Standir.rg counsel for the Income Tax Department contends that those u'ould unnecessarily burden the Income Tax Depaftment where they woutd be required to fiie equal number of SLPs belore the Hon'ble Supreme Courl and it would be fufther burdening the exchequer of the Union of India' It was also the contention of the leamed Standing Counsel that no prejudice would be caused to the interest of the petitioners in case if this writ petition is kept pending tilt the finalization of the SLPs pending before the Hon'ble Supreme Court and the fact that the petitioner is already enjoying the benefit of interim protection' Nonetheless' on the earlier query of this Court as to why the Income Tax Department have not come out with a mechanism to issue appropriale instructions or to take 7 _-_- appropriate steps in ensuring that proceedings uncler Section l4gA of the Act as also the assessment orders under Section 14g of the Act ar.e kept in a hotd in the light of the decisions dedcided by the . v4qiq.us Ilieh .-Clquf_s, ii w-as_suhr-1i[e_d by-.thc-._t_ea{ued.Stq{Lduc- Clounsel that rhe said steps can only be taken at thc Ievel ol CBDT as any sur:h steps would have to be taken pan India and cannot be limited to uy of these jurisdictional High Courts. 10. As a resLrlt of which, what we are lacing is steep increase of Iitigation day in and day out even though various orclers have been passed bv this lJigh Court allowing writ petitions on the very, sarne issue.'fhe Income Tax authorities concerned are stili even novv in 2025 also initiating proceedings in contravention to the provisions of Secrion I i L,\ ol tlte Act and as a result by now, rnore than 600 to 700 petitions have been already got piled up belbre this High Court on an issue rvhich otherwise stands squarely covered by the judgment of this Cour.t in the case of Kanakala Ravindra Recld-y ( 1 supra). Whar is also surprising is the fact that though while allowing the 'a,r-it petitions in the case of Kanakala Ravindru Red$r (1 supra), rhe Division Bench while reseruing the right of the Revenue, has also protected the lnterest of the petitioners 8 insofar as the liberty which was granted to the Revenue for initiating fresh proceedings strictly in accordance with the amended provisions of the Act, as amended by the Finance Act' 2020 and the Finance Act,202l'The petitioner assessee would be entitled to challenge or raise the other legal objections if the Revenue initiatcs fresh proceedings' The Department has made no endeavour in availing the said libefty that was reserved for the Revenue' On thc contrary, they have been still sticking on to the stand' which this Fligh Court as well as marly other High Courts already hcld to bc bad.

11. It appears that because of the aforesaid liberly that this High Coud had granted permitting the Revenue for initiating tiesh proceedings as a one-time measure ln a faceless manner, the Income Tax Depaftment wants to take advantage of the same by protracting these proceedings which would enable them to meet the limitation that would otherwise come in the way' Likewise' if the writ petition is kept pending for a considerable long period of timc and finalty at a later stage if the Hon'ble Supreme Court confirnis the decision taken by this High Court as also by the other High CourlsinwhichthesLPsarestillpending,thelncomeTax ,.. 9 Depar-tmcnt would get the advantage of the libefty that is otherwise protecteci in i'avour of the Revenue for initiation of fresh proceedings 1rom the disposal ol these matters at a rnuch later stage which would be advantageous and beneficial to the Revenue and would be equally disadvantageous and detrirnental so f.ar as interest of the assesses are concemed. As a consequence, the Income Tax Departmcnt gets an extended period of time for initiation of fi.esh proceedings,

12. The alarm ing trend of docket explosion in this Court, despite the clear plecedent sel jn Kttnakolo Rnvindro Redrtl, (lsupra), is a Inatter o1- graye concem. The Income Tax Deparlment,s per.sistent initiation of fi.esh proceedings, disregarding the established judicial pronouucements. has led to an unprececlented surge in litigation with over 600-700 petitions piling up on the same issue. Ihis deliberate app:oach not only undermines the principle of judicial precedent but also strains the judicial resources umecessarily. .lhe Depaftmenl's strategy of awaiting the Supreme Court,s decision on pending SLI)s while continuing to initiate fresh proceedings appears to be a calculated move to buy time and circumvent limitation pc:iods, r-ather than adhering to the established Iegal 10 position. Such conduct raises serious questlons about the and the respect for judicial administrative efficiencY pronouncements, parlicularly when this Court has already provided a balanced approach by preserving both the Revenue's rights and assesses interests

13. Another aspect which needs to be considered is that in fact it should havc bcen realized by the Incorne Tax Departrlent itself and should have lound out via media in ensuring that proceedings under Sections t48-A and 148 should not have been issued in a faceless manner, at least till the Hon,ble Supreme courl decide the twelve hundred (1200) odd SLPs which it is already seized ofor' at least the Income Tax Department should have found out solne remedial steps to ensure that wherever the authorities intend to initiate proceedings under Sections 148-A and 148' other than in a faceless manner, the proceedings should have been defened without precipitating the matter further intimating the assessee that they shall initiate appropriate proceedings only after the SLP's are decided by the Hon'ble Supreme Court on the very same issue' This again, the Income Tax Department' has not been able to give a convincing reply, except for the fact that such a decision if at all ......-.L 11 has to be taken, has to be tal<en lor the whole of India, and which otherwisr: fras to be by way of a policy decision and that too at the level of Central Board of Direct Taxes. Though the leamed Standing Cotrnsel for the Income Tax Department contended that the Delhi High court dismissed a writ petition of similar nature, on the one hand when the High Courl is struggling to reduce its pendency, s;uch notices which at.e under challenge in this writ petition are lorcing the assessee to lorock the doors o1 this I{igh Court rcsulti,g i, filing ol-hu,dr.eds of neu,writ petitions u,hicl.r in the long run not only aflects the disposal of the writ petitions but also consumes substantial time of the Bench in hearing these matters again and again on daily basis. Adrnittedly, in spite ol.the rnattel befirre the Hon,ble Suprcrne Court having been taken on man1, occasions. the FIon,ble Suprerne Court which is seized of the matter has becn reluctant in granting any interim protection to the Income Tax I)eparlment. yet, the authorities concemed at the State level are not ready to accept the verdict passed by a major.ity of High Courts of different States on the same issue; and to make things further worse, the Income Tax Department is showing audacity by issuing notices continuously under Sections 14g_A and t2 148 through the jurisdictional Assessing Officer whereas it ought to have been only in the faceless manner'

14. In the case ol BANK OF INDIA vs. ASSTSTANT COMMISSIONER, INCOME TAXIr' on an issue whether it was justifiable on the paft of the lncome Tax Department in not foltowing an order passed by the adjudicating authority only on the ground that the appeals are pending' the Division Bench of the High Court of Bombay held at paragraph No'25 as under' viz'' : '25. Mr. Paridwalla has rightly drawn out attention to the decislon of this Court in Commissioner of lncome Tax vs' Smt' Godavaridevi Sarafl2 as also the recent decision of the co- ordinate Bench of this Court in Samp Furniture (P) Ltd' v' lTOl3 of which one of uS (Justice G.S, Kulkarni) was a member, Wherein the Court categorically observed that the Revenue having not "accepted" the.iudgment of the High Court would not mean that till the same is set aside in a manner known to law' it would loose its binding force Referring to the decision of the Supreme Court in Union of lndia vs' f"*t"k"t'i Finance Corporation Ltd'14' the Court observed that the approach of the officials of Revenue of treating decisions being "not acceptable' was criticized by the Supreme Court ln such decision' following are the relevant observations made by the Supreme Court' 1120251170 taxmann.com 422 (Bombay)l t' 1t9u 81 113 ITR 589 (BombaY) " izoz+1165 taxrnann.com 581/300 Taxman 452 (Bombav) 'o legZl taxmann.com 16155 ELT 433 (SC) 13 '6. Sri Reddy is perhaps right in saying that the officers were not actuated by any mala fides in passing the impugned orders. They perhaps genuinely felt that the claim of the assessee was not tenable and that, if it was accepted, lhe Revenue would suffer. But what Sri Reddy overlooks is that we are not concerned here with the correctness or otherwise of thejr conclusion or of any factual malafides but with the fact i n th eir concrusi"., or-r".::.t ::: :::l:,I ;lt:l: regard to the same issue which were placed before them one of the Collector (Appeals) and the other of the Tribunal. The High Court has, in our view, righ y r;riticized this conduct of the Assistant Collectors and the harassment to the ass€ of these orricers to n,""'t";:;"';"il'I:J:':; a uthorities higher to them in the appellate hierarchy. lt cannot be too vehemenfly emphasized that jt is of utmost rmportance that. in disposing of the qrasryudicial issues before them, revenue officers are bound by the decisions of the appellate authorities. The order of the Appellte Collector is binding on the Assistant Collectors working within his jurisdiction and the order of the Tribunal is binding upon the Assistant Collectors and the Appellate Collectors who function under the jurisdiction of the Tribunal. The principles of .ludicral discipline require that the orders of the higher appellate authorities should be followed unreservedly by the subordinate authorities. The mere fact that the order of the appellate authority is not ,,acceptable,, the department - in itself an objectionable phrase _ and is the subject matter of an appeal can furnish no ground for not following it unless its operation has been suspended by a competent court. lf this healthy _/ n. t4 rule is not followed, the result will only be undue harassment to assesses and chaos in administration of tax laws Additional observations IZ We have dealt with this aspect at some length' the learned it has been suggested bY because Solicitor General that the made by the High Court' have been harsh on the officers. lt is clear that the observations of the High Court, seemingly vehement' and apparently unpalatable to the Revenue' are only intended to curb a tendency in revenue matters which' if allowed to become widespread, could result in considerable harassment to the assesses-public without any benefit to the Revenue. We would like to say that the department should take these observations in the proper spirit. The observations of the High Court should be kept in mind in future and the utmost regard should be paid by the ad'iudicating authorities and the appellate authorities to the requirements of judicial discipline and the need for giving effect to the orders of the higher appellate authorities which are binding on them." I 5. What is woffying this Bench more is the fact that an endeavour is being made whole heartedly to ensure not to generate further litigation on issues which have been laid to rest by a large number of High Coufis all of whom have taken a consistent stand that the action of the lncome Tax Deparlment being violative of the 15 Finance \<:t, 2020 and Finance Act, 2021 . Now, in order to protect the inter.erst of the Revenue as also that of the assessee, it would be trite a1 this juncture, if u,e disposc of the writ petition with an o bservation/direction that the disposal of the instant rvrit petition in tenns of the judgment rendered by this High Court in the case of Konkunola Ravintlra Reddy (r supra) shall however be subjcct to the outcorne of the SLps which rvere filed by the Income Tax Depaftment and which is pending consideration before the Hon,ble Supreme Couft.

16. In the given facts and circumstances, this tsc.nch is of the consider.ed opinion that unless and until we do not timely dispose olmatters rvhich are squarely covered by the decision of this Court aud which stancls fortified by the decisions of the 'arious other t{igh Courts on the very same issue, the pendency ot.this Fligl,r Court would furlher be burdened which otherwise can be decided and disposed of as a covered matter. I1 . So far as the inter.est of the Revenue is concemed, u,e are of the considered opinion that the interest of the Revenue has already been consider:ed and protected, as has been observed in paragraphs t6 36,3Tartd38oftheorderwhich'forreadyreference'isreproduced hereunder: The notices per se illeg

36. For all the aforesaid reasons' the impugned notices issued and the proceedings drawn by the respondent- is neither tenable, nor sustainable Department so issued and the procedure adopted being al, deserves to be and are accordingly set As a consequence, all the imPugned aside/quashed. uashed, the consequential orders passed orders getting q by the respondent-Department pursuant to the notices issued under Section 147 and 148 would also get quashed and it is ordered accordingly The reason we are quashing the consequential order is on the principles that when the initiation of the proceedings itself was procedurally wrong' the subsequent orders also gets nullified automaticallY'

37. The preliminary objection raised by the petitioner is sustained and all these writ petitions stands allowed on Since the impugned notices this very jurisdictional issue quashed on the Point of and orders are getting jurisdiction, we are not inclined to proceed further and decide the other issues raised by the petitioner which raised and contended in an stands reserved to be approPriate Prcceedings

38. Since the Hon'ble Supreme Court had' in the case of Ashish Agarwal, supra, as a one-time measure exercising the powers under Article 142 of the Constitution of lndia, permitted the Revenue to proceed under the substituted provisions, and this Court allowing the petitions only on the procedural flaw' the right 17 .lonferred on the Revenue would remain reserved to proceed further if they so want from the stage of the order of the Supreme Court in the case of Ashish l\garwal, supra. I 8. Wt: ,vould only further like to rnake observal.ions that since rve are inclined to dispose of the instant wr.it petition, conscious of the fact that the earlier order ol this High Courl in the case of Kanakala Ravindra Redtty (1 supra) is subjected to challenge befbre thr: Hon,ble Supreme Court in SLp No.3574 of 2024,, pref-erred by tlie Income .l.ax Deparlment, we makc it clear that allowing of the instant writ petition is subject to ourcome of rhe aforesaid SLP prefer:red by the Revenue against the decision of this t{igh Court in the case of Kanakalo Ravindro Redrty (l supra). 'lhis, in other u,ords, would mean that either of the panies, if they so want' rnrly lllove an appropriate petition seeking revival of Lhis ri,rit petition in the light of the decision of the Hon,ble Supreme Court in the pentling SLp on the very same issue. ( ( 19 Accordingly, the instant writ petition stands allowed hvour of ttre assessee so far as the issue of jurisdiction ls concernecl. .As a consequence, the impugned notice under challenge under Sections l4g_A and l4g stands set aside/quashed. 18 orders' if any, also stand set aside/quashed The consequential similar terms as have been Passe d bY this High Court in the case ol (1 supra)' There shall be no order as Kankanala RavindraRerlr/y to costs. Consequently, miscellaneous petitions pending' if any' shall stand closed To, I The Ministry of Finance' 100 011. ,'R,Hs:$sH / //TRUE COPY// Union of lndia' lncome T SECTION OFFICER epartment' New Delhi - artment, Ministry of Finance'

2. The Com Governm missioner' ent of lndia, New e Tax DeP Delhi - 100 01i 37 (P) of

3. The lncome Tax Officer' Ward 3 ( 1), Hyde rabad lnco me Tax DeP artment P) of KondaP Office, 727,s ignature Towers, SY No.b( mpallY (M Kothag uda, OPP Botantc al Gardens' Serilinga 084. Ema ad, Telang hone. Plus incometa ana - 500 x.gov.in P ur, SY. No ), Ranga reddY gt - o+o 23485421 , Hyderab District hyderabadito

3.1@ 4 The National Face less Assessm ent Centre, lncome Tax DePartment' tvlinistry of Finance, Govern ment of lndia , New Delhi - 100 01 '1 . 5. One CC to SRI SHEETAL SRIKANTH, Advocate tOPUCl 6. One CC to SRI GADI PRAVEE N KUTUAR, ( DeputY Solicito r General of lndia), SC for lncome Tax DePadment' [OPUCI 7. One CC to Ms B'SAPNA REDDY' B. Two CD CoPies' Hish Court for the State of Telangana at HYd erabad toPUCl o BSK GJP HIGH COURT DATED:02 tOTt2I2s I ORDER ,:.?-. [7 0[T 2gg WP.No.18t0t of 2O2S \i- r- ' ../ )t' ALLOWING THE WRIT PETITION WITHOUT COSTS