The High Court · 2025

THE HON'BLE THE ACTING CHIEF JUSTICE P.SAM KOSHY AND THE HON'BLE SRI JUSTICE NARSING RAO NANDIKONDA WRITPETTTI ONNO.20943oF 20ZS ORDER (per Hon'ble Sri lustict P.Sam Koshy) Heard Mr. T.Chaitanya Kumar, learned counsel for the petitioncr and Ms.B.Sapna Reddy, Ieamed Senior Standing Counsel for tlrc lncome Tax Department appearing for the respondent Nos'l and 2' and Mr. C.Venkateswarlu, leamed counsel representing Mr' Gadi Praveern Kumar, learned Deputy Solicitor General of India' appearing for rcspontlent No.3. Perused the record'

2. Tl'ris is a writ Petition where the proceedings are either challt'rrgeci to the notices which were issued under Scction .148A l48 ot thc ltrcome Tax Act, 1961 (for short'the Act') or the assessment ordt'rs those have been passed under Section L47 of ttlc Act which lra vt' [.t't't-t arssailed.

3. l his writ Petition is being taken up today only ot-t onc o[ thc grouneis, that the notices issued under Section 148A of the Act 'llc'l the sul,st'qucnt initiation of proceedings under Section 148 of the Act by tl-re ju risr.l ic tional Assessing Officer, whereas in tt'rms of the amentlrnetrt that was brought to the Income Tax Act Lry way of [rinatrcc Act, 2021 w,c'.f., 01.04.2021 onwards' proceedings under Sc'ction 148A { 2 of the Act as also under Section 14g of the Act ought t r have also been issued and proceeded in a faceless manner.

4. The contention of the petitioner is that the is:;r e of proceedings being in violatio^ of the Finance Act, 2021 i.e., the : npugned notices under Section 148.4 and Scction 14g of the Act not rcing issued in a faceless manncr, have arreatry been dealt with arc decided by this Court in the case of I(ANKANALA RAVINIT i.A REDDy vs. INCOME-TAX OFFICEI(I rlccidcd on 74.A9.20,23 ral ereby a batch of writ petitions n erc ;illon,ccl a.c1 thc proceedings initie .ed under Section 1484 as also urclcr Sectio. r48 of the Act were h<.r r to be bad with consequential relicfs on th. grourrd of it being i r violation of the provisions of Sccri.rr 15lA of rhe Act read with Nr ification lg / 2022 dated 29.03.2022. f hc sair.[ jut{g.-rerrt passecl by this (] rurt has also been subsequentlv follo*'ctl i, .r tar.rle .umbcr of writ pet tions which were allowed on sint ila r tcruts.

5. Down tlr. lir.., r'r, li.d that thc. same issue has, riso been decided against the Revcnuc lrv variorrs Hi1;h Cour.ts i.e., b1, he Bombay High Court in the casc of HL.XAWARE TECHNOLT_ GIES LTD., vs. ASSISTANT COMMISSIONER OF TNCOME TI X & OTHERS,, Gauhati High Courr in rhc casc of I{AM NARAYA}I SAH vs, UNION '[(2023) I56 taxrnann.cnrn 178 l felangana)] ' lzoz+1464 I'll( .l3o ( tsoril) 3 OF INDIA3, Punjab and Haryana High Court in the case of |ATINDER SINGH BANGU vs. UNION OF INDIA4, and Telangana High Court in the case of SRMNKATARAMANA REDDY PATLOOLA vs. DEPUTY COMMISSIONER OF INCOME TAX5 where the issue was in respect of international taxation, Bombay High Court in the case of ABHIN ANILKUMAR SHAH vS. INCOME TAX OFFICER, INTERNATIONAL TAXATION6 which is again on international taxation ancl central circle, High Court of Himachal Pradesh in the case of GOVIND SINGH vs. INCOME TAX OFFICERT, Gujarat High Court in thc case of MANSUKHBHAI DAIryABHAI RADADIYA vs. INCOME TAX OFFICER, WARD 3(3X5)8, Jharkand High Court in the case of SHYAM SUNDAR SAW vs. UNION OF INDIAe, Rajasthan Higl.r Court in thc case of SHARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER and batch of writ petitionsro which stoorl decitleci on 19.0J.2024. Similar views have also been taken by tlrt' Division Bencli o[ Calcutta High Court in the case of GIRDHAR ' [(2021) 156 taxrtranrt.conr 478 (Gauhati)] ' [(2024) I 6-5 taxurann.com l l5 (Punjab & Haryana)] '[20211 167 la\nlann.coln 4l I (Telangana)] " [2024) I(16 tarrnann-conl 679 (Bombay)] '[2024) 165 taxnrann.corn tl3 (Hirnachal Pradesh)] t202+ SCC Orrline (iu,| 4012 " 202-5 SC'(' OnLine Jhar 287 t('12oz,l : RJ-.rD:4981-DBl 4 J:.' GOPAL DALMIA vs. UNION OF INDIA & OR! (M.A.T 1690 of 2023), decided on 25.09.2024

6. Even though the same issue having been d: ided by a large number of I Iigh Courts, we are still confronted u i h large filing of -: identical matters on daily basis ranging between 5 to 10 writ petitions That upon the instructiorrs being sotrght from the )epartment, they have been taking a solitary grourrcl that the decisic r of the Bombay High Court in ihc case of Hcxauttrc Tcchnologies Ll4 , (2 supra) as also the one which has been clecidecl by this Court in th: case of Kanakala Raoindra Rcddy (7 supra) has bcen sulricctecl to ch,r lenge in a Special Leave Petition i.e., SLP No.3574 of 2024 before thr, Hon ble Supreme Court and thc Hon'b[. Supremt' Coult is seiz: I of the matter. ln addition, there are about 1200 5l .l's also filcd arisi rg out of the same issue being decicled b1, v;rrious I lirglr Corrlts

7. To a qucly bt'ing put to thc lt'.rrnctl counsel fc r the Revenue, they have categorically acccptcd thc t.rct that therc i; no interim order Sranted by the l{on'blc Su 1-'11'11q1' Court irr any of th: e matters pending before it. Mcanwhile, ftcsh rvrit petitions of ic{enti:,1 nature are being piled up beforc this Bcnch on da ilr, l,asrs .rntl tht' 1 :ndency is getting increased or1 mattcr which othcrwisc h.rs alrca,i r been dealt and decided by ihis very Hir;h Court itscll 5

8. On the one hand, even though the order of this Court that was passed as early as on 14.09.2023 and more 16 months have lapsed, till date, we do not find any remedial steps having been taken by the Income Tax Department to take appropriate stePs to either hold back issuance of notice under Section 148A and under Section 148 of the Act by the jurisdictional Assc'ssing O(ficer, rather the authorities concemed in the teeth of series of ciecisions by all the major High Courts in India are continuousty still initiating proceedings under Section 148,{ of the Act and also initiating proceedings under Section 148 of the Act in contravention to the amendments brought into the Income Tax Act pursuant to the Firrance Act, 2020 as also the Finance Act 2021,.

9. Upon a query beirrg Put as to why can t this writ Petition be disposed of in the tceth of the decision rendered by this Court in the case of Kataktla Ruuindrt Reddy (7 supra), learned Standing Counsel for the Incor-r.re I.rx Dt'partment contends that those would unnecessarily burrlen thc [ncornc Tax Department where they would be required to file tqual num[rer of SLPs before the Hon'ble Supreme Court and it woulcl he further burdening the exchequer of the Union of India. It was also the contt'trtion of the learned Standing Counsel that no preiudice woultl [-,e causet{ to the interest of the petitioners in case if this u'rit petition is kt:1-rt pend ing till the finalization of SLPs .the, 6 pending befole tl-re Hon'ble Supreme Court arr -l the fact that the petitioner is already enioying the benefit of rterim protection. Nonetheless, on the earlier query of this Court as o why the Income Tax Departrnent have not come out with a rr:chanism to issue appropriate instructions or to take appropriate st I )s in ensuring that proceedings uncler Section 148,4 of the Act as . so the assessment orders under Section 148 of the Act are kcpt in a lro ,l in the light of the decisions decided by the various I'lig['r Courts, it v, s submitted by the learned Standing Counsel that tl'rc saic{ stePs carr c Lrly be taken at the level of CBDT as any such steps u,oulcl havc to bc r rken Pan India and cannot be limited to any of these jurisclictional I Iiglr Iourts.

10. As a lesult of which, what rve are facirrq s steep increase of litigation day in and day out evcn though v.trit,L ; orders have been passed by this High Court allowirrg w,rit [r('trti() r on the very same issue. The lncorne Tax authorities cc'rncc'rnctl .rlr' .t I e\.ct1 llow n ZO2S also initiating proceedings in corrtravt'ntion to tlrt' 1 r rx,,isions of Section 1514, of the Act and as a result b), n()n,, nrLr-c tlta r 6(X) to 700 petitions have been already got piled up bclorc this I[i;rl Court on an issue which otherwise stands squarely covcrcrl bv tlrc iL ( snlent of this Court in the case of Katnkala Raainlm Rcdd1 0 .,r pra). What is also surprising is the fact that though whilc allor.r.ir-r11 tl.t rvrit petitions in the case ol Kartakala Raa ulra Redrty (7 supra), the Division Bench while reserving the right of the Revenue, has also Protected the interest of ttre petitioners 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 try the Finance Act, 2020 and the Finance Act, 2027. The petitioner assessee would be entitled to challenge or raise the other tegal otriections if the Revenue initiates fresh proceedings. The Department has made no endeavour in availing the said liberty that was reserved for the Revenue. On the conhary, they have been still sticking on to the stancl, rvhich this High Court as well as many other High Courts alreadv hclLl to Lre bad.

11. It appears that because of thc aforesaid liberty that ttLis High Court had granted permitting the Revenue for initiating fresh proceedings as a one-time lllcclSllrt' in tr faceless manner, the Income Tax Department wants to take atlr'.ltttage of the same by protracting these proceedings which rvoulti etra['le thern to meet the limitation that would otherwise cotne in the n'av. l.ikcrvise, if the writ Petition is kePt pending for a considerable long periotl of time and finally at a later stage if the Hon'ble Supretne Court confirms the decision taken by this High Court as also by the other FIigh Courts in which the SLPs are still pending, the [ncome Tax Deprartment r'r'ould get the advantage of the 8 liberty that is otherwise protected in favour of tlrr: levenue for initiation of fresh proceedings from the disposal of these rr ttters at a much later stage which would be advantageous and benefici I to the Revenue and would be equally disadvantageous and dctrim(,rrr rl s() far as interest of the assesses are concerned. As a consequrr:e, thc Income Tax Department gets an extended period of tim<, I rr initi;rtiorr of fresh proceedings.

72. The alarming hend of docket explosion in ris Court, clespite the clear precedent set in Katakala Rao ulra Rcdd 1 fi sLrpra), is a matter of grave concern. The Income Tax Department s )c.siste.t irritiation of fresh proceedings, disregarding thc , statrlishecl judicial pronouncenenls, has led to an unprecedentetl ,, r11e. in litillation with over 600-7fi) petitions piling up on ttrc samt, ssur,. .l his tleliberate approach not only undermines the prir-rciple c,t .rtlrr.ial prcceclent but also strains the judicial resources unnocess.t r r ;. I lrt, [)e partment,s strategy of awaiting the Supreme Court,s rlt,cr..rr.r ,rn lr,nriing SLp. while continui.g to initiate fresh proccec'lirss al.,l ,.. s r. [r. a calculated move to buy tirne and circumvent lirnitatror P(,n()(ls, rathcr. than adhering to the established legal position. Such orrtluct r..riscs serious questions about the administrative efficicncy il.r(L hc rcspect for,udicial pronouncements, particularly when this Court I rs alrcarJl provided a 9 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 have been realized by the Income Tax Department itself and i l l should have found out via media in ensuring that proceedings under Sections 148-A and 148 should not havc becrr issued in a faceless manner, at least till the Hon'ble Supreme Court clecide the twelve hundred (1200) odd SLPs which it is alrc'acly seizccl of or, at least the Income Tax Department should have found out some remedial stePs to ensure that wherever the authorities intcnd to initiate proceedings under Sections 148-4 and 148, other than in ;r faceless manner, the proceedings should have been deferrecl r,vithout prccipitating the matter further intimating the assessee that thcv shall initiate aPProPriate proceedings only after the SLP's are tlecitletl I.'r' tlre [lon'ble Supreme Court on the very same issue. This agairr, tht' ltrcotrle'Iax Department, has not been able to give a convincinll reprh" t'tt"ot for the fact that such a decision if at all has to be takcn, has to ht' taken for the whole of India, and which otherwise has to Lrs bl' tr'.11' ot a policy decision and that too at the level of Central Boarti of Dircct '[ axes Though the leamed Standing Counsel for the Incomt' '[ ax DePartment contended that the Delhi High Court dismissed a rt'rit pctition of similar nature, on t0 the one hand when the High Court is struggling to reduce its pendency, such noticcs wl-rich are under challenge in this wr_i petition are forcing the assessee to knock the doors oI this High Cotu t resujting in filing of hundrecls of new writ petitions which in the lorrl; run not only affects the disposat of the writ petitions but also co^srrr.. ; substantiar tirne of the Bencl-r in hearing these matters again and ,r ,air.r on rlail_y [asis. Admittedly, in spite of the matter before the Hor blc Suprrcnlll 6.r., having becn taken on many occasions, thc Horr :rle Suprt,mt, Court wlrich is seized of the matter has been reluctant irr , rantirrg arrv i.terinr L)rotection to the Income Tax Departrnent. t,t, the ,ruthorities concerncd at thc State level are not reacly [o accc: tht. r,crrlict passetl by a rnajority of High Courts of different States .rr :l.rc saure issut, ;rncj to tn;rke things further worse, the lncorne Tax Dc1 ll.tnrcr][ r, slrorvinll audacity b1, issuing r-rotices continuously under St.- rons lJli_.\ anrl l.l,S through the ju risdictional Assessing Officer rvhcrc rs rl our;lrt to 11.11,,. been only irr thc faceless manner.

14. In rhc case of BANK OF INDIA vs. ASSISI.ANT COMMISSIONER, INCOME TAX1], on an lss r r' u,hcthcr. it w,as justifiable on the part of the Income Tax Depar.tmer I rn uot follon.rng an order passccl by the adjudicating authority only or hr, 1;rourrtl that the '' J12025y I;rr r a x nra nn.corn 422 (B onbay)l 11 appeals are pending, the Division Bench of the High Court of Bombay held at paragraph No.25 as undel viz., : "25- Mr. Paridwalla has rightly drawn out attention to thc, tlecision of this Court in Commissioner of Income Tax vs. Smt. Godavaridevi Sarafi2 as also the r6cent decision of the co-orclinate Bench of this Court in Samp Furniture (P) Ltd. v. ITOr: of which one of us (Justicc G.S. Kulkarni) was a member, wherein the Court categoricallv observcd that the Revenue having not ,,accepted,, the iudgrnc,nt of the High Court would not mean that till the same is set aside in a manner knoq,n to iaw, it would loose its binding force. Referring to the d(,cisknr of thc Suprcme Court in Union of India vs. Kamlakshi Finance Corporation Ltd.ir, the Court observed that the approach of the officials of Rcvcr.ruc ()f treating decisions being "not acceptable,, was criticizecl by thc Supr.om(, Court_ hl such decisiorl foltowing are the relcvant obscrvahtrrr; nr.rilt, trv the Supreme Court. "6.Sri Reddy is perhaps right in saying that rhe r,[fit,rs rrtrc not actuated by any mala fidcs in passing rhc irnprrlin(,1l orders. They perhaps genuinely felt that tht,t.lainr ot rhc assessee was not tenable and that, if it rvas acccptt,rl, tlrr., Revenue would suffer. But what Sri Recldl,ov<,rlrrrrls is that we are not concemed here with the c()rr(,cht(,ss ()r ()tlrrrlr\.is(, of their conclusion or of any factual malafirlt,s [rut u,rtlr tlrt, fact that the officers, in reaching iu thr,ir r.onc.lusron, hr,,- passed two appellate orders in regard to tlre sarrrc is.,trc which were placed before them, onc o[ thc Collt,t.hrr (Appeals) and the other of the Tribunal. The lligh Corrrt h.rs, in our view, rightly criticized this conclLrct o[ th(, Assist.lnt Collectors and the harassment to the asscsse(, c.ruse(l bv thp '' 1 tsz81 I ti ITR 589 (Bombay) " p0zn1 165 taxmann.com 581/300 Taxman 452 (llonrbay) '' 1 loo2; raxmann.com l6155 ELT 4-13 (SC) i i l 1 1i I l I i I 72 to ot" effect to llc' orders of failure of tltese officers authorities l.righer to ,n", ca*ot be ,.. ,*"-*r;.;oo::;:T:", ;:1;.:;",7 importance that, in disposing of the quasi r :riciar issues bcfore them, revenue officr ut" *"to by tl t ciecisions of thc appelrate audrorities. ,ttt order of the Ap[ ( lte collector is bintring on tr," e""tt ohe Collectors wo'ki I ; witltin his luriscliction und U," o.d". ol't is hin I ng upon the A.ssista.t Colecrors u.,o .1" 'nou^al rur.rcri<,. under *" ,**o,lr*oT"T: ;];:^ ;ll pri,cip/es of judicial discipline require that the c _ders o[ tlrt, highcr appellate authorities s d be followed u trescrvcdrl by the subordinate authodtie or rhc apperare ",;;;"_1"..*;:fij, .:T*1: (lcP.rrtmcnt _ in itself an objectionable phrasc _ and is the srrtri('ct nrattol of an appear can fumish no grc L rd for not folkru,,in1, it unless its operation has been suspe rcled bv a ) t , I ( , I I I court. Jf this hea *'" is not fr'r rwc.ri, trre r.t,surt wi[ o,ry be undue ha.u"t*' sment to assesses ; r :r crr,ros in .rtrrnirristratiorr of hx raws. ( r , I I r I I l. [\i. h.rvt, (iealt with thi has b,,cn sugi;csted, ;:':I]l'"rj*ll;,;.H: Ccncra I that the observatiot ns made by the High (i u.t, Iravt, lrct,rr rrar.srr o. tr.re officers. r,, rr r;h ..".,,,"";;;'H*:,.":::..; Lt tr|.,I.r t.t blt' t. the Reve,ue, arp ^hr,, :_a- r , ttlrtlc^c' irr rg1,gnr" *u,aur' u'itr.sp11,a1r, courd 1s5u11 ,s .rsscsscs-r,ublic *,,...,, .", u,oultl lrke to sav that the 1'b:,., v. rr\,^s,",,", r."0".-"01j;-T"il::: j, "JT:: Hrllh ( ,ru rt shr.rulcl ht ktpt in mind in fufure and rl t utm,rst :::l:JJ '! t''rrLrt , u'" only intendetl t currr .r which' if allowed lc bec.rre r",.","; I "ilj,i',1' Jli . : I / I i I *= 13 regard should be paid by fte adjudicating authorities and the appellate authorities to the requirements of iudicial discipline and the need for giving effect to the orders of the higher appellate authorities which are binding on them."

15. What is worrying 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 largc number of High Courts all of whom have taken a cpnsistent stand that the action of the Income Tax Department being violative of the Finance Act, 2020 and l:inance i I \ I i I i I i i Act,2027. Now, in order to protect the interest of the Revenue' as also that of the assessee, it would be trite at this juncture, if we dispose of the writ petition with an observation/direction that the disposal of the instant writ petition in t€rms of tlre judgment rendcret{ by this I ligh Court in the case of Kankanala Raoindra Reddy (1 supra) shall however be subject to the outcome of the SLPs which n'ere filccl lrv the lncome 'fax Department and which is pending consiclcration befort' the [{on'Lrle Supreme Court.

76. [n the given facts and circumstances, this Bench is ot the considered opinion that unless and until we do not timelv r.lis1'ost' oi matters which are squarely covered by the decision of this Court ancl which starrds fortified by the decisions of the various othcr [ ligh Courts on the very sarne issue, the pendency of this High Court r,'ou[d further t ; 74 be burdenecl r.vhich otherwise can be decided a.,tl disposed of as a covered r.na ttcr

77. So far as the interest of the Revenue is conc:rned, we are of the considerecl opinion that the interest of the Reven re has already been corrsiciererl arrri protected, as has been observecl i r paragraphs 36, 37 ancl 38 of thc ordcr which, for ready refer,: rce, is reproduced hereu ntlcr "lt'. [or all the trforesaicl reasons, the impugnec notices issued arrrl tlrl' plllceeclings dra,,r,n Lry the responden:- )epartrnent is ncitlrt.r tcnalrlc, nor sustainable. The notices so ;sued ancl tl.re ;.r'r,t-ctltrrc artoptcd t)eing per * illegal, deserves to be ancl ar.e ,r.(r)rrlirl'lv set aside/quashed. As a conse<. ence, all thc ittrptrglll'.1 ()rdcrs gctting quashed, the canse,l ieltial orders plsscrl [Tv thc resp.rorrdent-Departrnent pursuant :o the r.roticcs isstrcrl rrrrrlcr Scction l42 and 14g would also get ( uashecl ancl it rs ()r'cl(,r (,([ .rct.orrlinglv. Tlre reason we are luasl.ring thc crrrrsr.'tlr-rerrtial ortlt,r is on the principles that wlxr of th1, p11r1-l,sclings itself was procedurall., su[rst't]ur.nI ordcls ;rlso gcts nrrllified automatical,r '1.. lhc plclinrin.rrv obiectiolr raised by th: petitioner is srrst.rurt-tl ,rntl all tht,se E,rit petitions stalds a I wed on this vt,lr ;rrrisrlictrorr.tl issuc. Sirrce the impugned not c ts anc{ orriers nr(' lrctti.l' tl.aslrt'd (). trrc poir.rt of jurisdicticr we are n()t ittclrrrccl to proccttl further and clecide dte other ir;r res raised tr1, tlle []ctiti()ner w,hich st.tr.rtls reserved to be raised r d contcnclcti itr arr ap1,11,1'r1.116, prrx-ccclin11s. the initiation wrong, tht, 15

18. Sincc the Hon'ble Suprerne Court had, in the case of Ashish Agarwal, supra, as a one-6me measure exercising thc powers under Article 142 of the Constitution of lndia, permitted the Revenue to proceed under the substituted provisions, and this Court allowing the peritions only on the prrredural flaw, the right conlerred on the Revenue tvould remain reserved to proceed further if tlrey so r+'ant from the stage of the order of the Supreme Court in the casc of Ashish Agarwal, supra." .18. We would only further like to make observations that since we are inclined to dispose of the instant writ Petition, conscious of the fact that the earlier order of this High Court in the case of Kanaktla Raaindra Reddy (7 supra) is subjected to challenge before the I lon'ble Sup'rrcme Court in SLP No.3574 of 2024, Preferred by the Income '[ ax Department, we make it clear that allowing of the instant writ petitiorl is subject to outcome of the aforesaid SLP preferred by the Rcvertue against thc decision of this High Court rn the case of Kanaknlrt Raaindra Rcdrty (l supra). This, in other words, would mean that cilher of the parties, if they so want/ may move an appropriat(' pctition seeking revival of this writ petition in the light of the decision of thc FIon'ble Supreme Court in the pending SLP on the very same issut'. 19 r\ccordingly, the instant Writ Petition stands allowed in favour of the assessee so far as the issue of jurisdiction is concerned Asr consequence, the impugned notice under challenge under Sections l'18- I I t, i l I l l l t5 A and 148 stancls set aside/quashed. The corueqrr rntial orders, if any, also stand sct asicle/quashed in similar terms as I lve been passed by this High Court in the case of Kattkanala Rauirt,).n Rcitily (1 supra). There shatl bc, rro order as to costs. Consctluerrtly, miscellaneous petitions per r ing, if any, shal stand closccl. //TRUE COPY// - S )/.P. PONNA KRISHNA AS:; STANT S REGISTRAR SECTION OFFICER ;5%6.J:".., I3Brli:ff iTlll,$;'' o}'pgL' I Faceress Assessn, nt ^centre, rncome ra x No. 4(', zno Fr"i,t:iiai,il Jawaharrar Nehru Srddium,?lt?l11i,SBBT The lncome tax officer. war{1,_Wgranqal/ lncome l.i x Office, D.No. 1_8_610 rr,rayuri comptex, opp isnpilidi;il;; '{ irrarrsuttr, retangans. The.SecretaU, Union of tndra, Ministry of Finance llorth Block, New Delhi_ One CC to SRI THANNERU CHAITANYA KUMAR, I\I Vocate. toPuc] 3,3i 33Ji 3I I f t?j,: H y55|, 5ffi [,!??3H:'. : i 1;',!o5,o" One CC to Ms.B.SApNA REDDY, SC for lncome Tax )epartment. {OpUCl Two CD Copies n",,' of , nd i a ) To, 1 2 3 4

5. 6 7 ,ht BSK GJP HIGH COURT DATED:1810712025 i I !-\ (J a- * r- J,A T I ,iAN 2|j2[ t i./ -Z L) -4t., ORDER WP.No.20943 of 2025 ALLOWING THE WRIT PETITION WITHOUT COSTS 0 ii'1 \?- I 1 I ,l