Courts i'e'' by the Bombay High Court in the case of HEXAWARE TECHNOLOGIES LTD v. ASSISTANT COMMISSIONER oFINCOMETAx&OTHERS

Petition under Article 226 of the Constitution of lndia praying that in the filed therewith' the High Court may be circumstances stated in iftu pleased to issue writ orolr oioiiection more particularly in the nature of writ of lvlandamus declaring tn" irpug;"J notice daied 2gt\3t2\24 bearing DIN and Notice No. ITBtuAST/s/1 4 a i i\zyzq 10636401 83(1 ) issued by.2nd respondent ,)r.i+a of th" tn"or" Tax Act, 1961 for A.y.2O2O-21 as being withoul jurisdiction, arbitrary, illegal, unjust and vioiative of Articles 14, 19 (1) g and 265 of Constitution of lndiaand lonsequently set aside the same and all consequent proceedings 'itiOuuit IA NO :1 OF 2024 PetitionunderSectionlslcPCprayingthatinthecircumstancesstatedin the affidavit filed in support of the petition, ift" fiigf' Court may be pleased pleased to stay all further proceedings pursuant to the notice dated 2910312024 bearing DIN and Notic: \o ITBA/AST/S/148 1t2O23- 24110636401.33(1) issued by znd respondent u/s 1z.B of the lncome f", n.f ig"6f ir Ay ZOZO t1 Counsel for th<: F,etitioner: SRl. MOHD MUKHAIRUDDIN Counsel for ther Resc,lndent Nos.1&2: Ms. B.SApNA REDD,/ SFl. SC FOR INCOME TAX DEPAII'TMENT -- -'-..' . COUNSCI fOr thc RESTIONdCNI NO.3: SRI B. MUKHERJEE REPRESENTING FOR sRl GADI pRAVEEN huMAR Dy. solicriiii'diiene. oF rNDtA The Court mader re .cllowing: ORDER -.-. -."raat) I THE HONOTJRABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTTCE NARSINGRAO NANDIKONDA WRIT PETITTO N No.27399 OF 2024 OR.DER' (per Hon'ble Sri Justice P.Sam Koshy) Heard Mr. Mohd. Mukhairuddin, learned counsel for the petitioner, Ms. B.Sapna Reddy, leamed Senior Standing Counsel for the Income Tax Department for respondent Nos'l and 2 and Mr. B. Mukherjee, learned counsel representing the Union of India for respondent No.3. Perused the record.

2. This is a writ petition where the proceedings are either challenged to the notices which were issued under Section 148A and 148 of the Income Tax Act, 1961 (for short 'the Act') or the assessment orders those have been passed under Section 147 of the Act which have been assailed.

3. This writ petition is being taken up today only on one of the grounds, that the notices issued under Section 148.4 of the Act andthesubsequentinitiationofproceedingsunderSectionl48of theActbythejurisdictionalAssessingoffrcer,whereasinterms of the amendment that was brought to the lncome Tax Act by way I 2 of Fin;rn:c ilrct, 2021 w.e.f., 0l .04.2021 onu.ards, proreedings under lier:rirn 14gA of the Act as also under Sectiln l4g of the Act ou1;hr tc, have also been issued and proceeded irL iL faceless manner,

4. The r: tntention of the petitioner is that the issue of proceedings t,eing in violation of the Financ e Act, 202 i.e., the impugne'J rtcltLces under Section I48A and Sectic,n l.1g oflthe Act not being issut:c in a faceless manner, have already been c errlt with and decided by this Court in the case of KANK.,\NALA RAVINDR.{ REDDY vs. INCOME_TAX OFI.ICERT decided on 14.09.2'.0?3 ,r,hereby a batch of writ petitions were alror.rt:d and the procee'Ii'gs initiated under Section I4gA as arso under S:ction 148 of the {1:f y,6;1e held to be bad with consequential reliefi; on the ground of il beirg in violation of the provisions of Section I,i A of the Act rea<l r,rir, Notification lg/2022 dated.29.03.2022. ,I,e judgment passed by this Court has also been subsequentl.,r fol lc,wed in a large nrrrbe- of writ petitions which were allov,ed rtn srnrilar terms. ' tQoZz)t sllexma ln.com I 78 (Tetangana)l :tat-t & I 3

5. Down the line, we frnd that the same issue has also been decided against the Revenue by various High Courts i'e'' by the Bombay High Court in the case of HEXAWARE TECHNOLOGIES LTD., VS. ASSISTANT COMMISSIONER oFINCOMETAx&OTHERS2,GauhatiHighCourtinthecase of RAM NARAYAN SAH vs' UNION OF INDIA3' Punjab and Haryana High Court in the case of JATINDER SINGH BANGU vs. UNION OF INDIA4, and Telangana High Court in the case of SRI VENKATARAMANA 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 OFFICE& INTERNATIONAL TAXATION6 which is again on intemational taxation and central circle, High Court of Himachal Pradesh in the case of GOVTND SINGH vs' INCOME TAX OFFICER?' Gujarat High Court in the case of MANSUKHBHAI 'lzozql464 ITR 430 (Bom) 'l(2024) 156 taxmann.com 478 (Gauhati)l '[(2024) 165 taxmann.com 115 (Punjab & Haryana)] '12024) 167 taxmann.com 41 1 (Telangana)l "12024) 166 taxmann.com 679 (Bombay)l ' [2024) 165 taxmann.com 113 (Himachal Pradesh)] I I 4 DAIIY{I}HAI RADADIYA vs. INCOME TAIK ()IIFICER, WARD 3(3xo8, Jharkand High court in the cast: of liHyAM SUNDAR SI.\,V vs. UNION OF INDIAe, Rajasthan Hrgrr Court in the case cf litrIARDA DEVI CIIHAJER vs. INCOIIE TAX OFFICTR & ANOTHER and batch of writ petirion: () stood dec,idecl an 19.03.2024. Similar views have als,t be e;r taken by the Divis;,orL Bench of Calcutta High Court in the case of GIRDHAR CirfpAL DALMIA vs. UNION OF INDIA {: ORS (M.A.T 169(r cr1.-1023), decided on 25.09.2024. 6. Even t-rorr6Jh the same issue having been deciriec by a large number of Hieh Courts, we are still confronted witb larl;e fiting of identical matrer: on daily basis ranging between -5 to I r) writ petitions. J'hiLt u con the instructions being sought fror.l the Department, thel. have been taking a solitary grounci thi.Lt the decision of the l}rmbay High Court in the case ,tf lle.wrutare Technologie.; Ltat., (2 supra) as also the one which has been decided by triir f,ourt in the case of Kanakala Ravittdra R,e,ldy 'z0Z+ SCC OnLine, jur 4ol2 '2025 SCC OrLrne Ihar 287 Io12o23: RJ-JD :498r -DBl 5 (1 supra) has been subjected to challenge in a Special Leave Petition i.e., SLP No'3574 of 2024 before the Hon'ble Supreme Court and the Hon'ble Supreme Court is seized of the matter' In addition, there are about 1200 SLPs also filed arising out ofthe same issue being decided by various High Coutts'

7. To a query being put to the leamed counsel for the Revenue' they have categorically accepted the fact that there is no interim order granted by the Hon'ble Supreme Court in any of these matters pending before it' Meanwhile' fresh writ petitions of identical nature are being piled up before this Bench on daily basis and the pendency is getting increased on matter which otherwise hasalreadybeendealtanddecidedbythisveryHighCourtitself.

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 l48A and under Section 148 of the Act by the jurisdictional Assessing Officer' rather the authorities concerned in the teeth of series of decisions t t 5 by alt thr nrrr;cr Fligh Courts iri India are ,;ontinuc usly stili initiating [)ro,]oedings under Section l4gA of rhe Act and also initiating prrrceedings under Section i4g,tf the Act in contraventitn to the amendments brought into the Inconte -lax Act pu-rsuant to tht. Finance Act,2020 as also the Finance Act1i02l.

9. Upon a query being put as to vrhy can't this wrLt pe,tition be disposed of in lhe teeth ofthe decision rendered by this rlourt in the case cf ,(u,ztkala Ravindra Reddy (l supra), learred l:itanding Counsel fitr the lncome Tax Department contends rhat thos,; would unnecessa:il y ;urden the Income Tax Department whe rr: they would be r,:qrured to file equal number of Sl_ps bef,tr.e the Hon'ble Sup,rr:rne Court and it would be further bui.denlrg the exchequer o1 th: Union of India. It was also the contentiorr lf the leamed Stanctinrr Counsel that no prejudiee would be causer.l .o the interest of the pe titioners in case if this writ petition ls ke:pt p,3nding till the firalizarJcn of the SLps pending beforr: rhe Hon,ble Supreme Crturt ru.Ld the fact that the petitioner is alread.y en jc,ying the benefit of int:rjm protection. Nonetheless, on the earlier cuery of this Court as tt why the Income Tax Department have not come out with a rnechtri.rism to issue apprcpriate instructions tr to take t--I 7 appropriate steps in ensuring that proceedings under Section 148A of the Act as also the assessment orders under Section 148 of the Act are kept in a hold in the light ofthe decisions dedcided by the various High Courts' it was submitted by the leamed Standing counsel that the said steps can only be taken at the level of GBDT as any such steps would have to be taken Pan India and cannot be limited to any of these jurisdictional High Courts' 10. As a result of which' what we are facing is steep increase of litigation day in and day out even though various orders have been passed by this High Court allowing writ petitions on the very same issue. The Income Tax authorities concerned are still even now in 2025 also initiating proceedings in contravention to the provisions of Section 151A of the Act and as a result by now' more than 600 to 700 petitions have been already got piled up before this High Court on un ,,tt'" which otherwise stands squarely covered by the judgment of this Court in the case of Kanakala Ravindra Reddy (1 supra). What is also surprising is the fact that though while allowing the writ petitions in the case of Kanakala Ravindra Reddy (l supra), the Division Bench while reserving the right of the Revenue, has also protected the interest of the petitioners t t I insofal a j 1b 3 liberty which was granted to the R<,venue for initiating rr::rh proceedings strictly in accordance u,ith rh,: amended provisicns rri' ihe Act, as amended by the Financ e .\ct, i,020 and the Finance 1*:t,2021. The petitioner assessee woulc be ,:rrtitled to . challenge itr raise the other legal objections if the Revenue initiates fresh prrtcr:eci,gs. The Department has made no endi)rvour in availing tht) siiLi I liberty that was reserved for the Revenu(r. On the contrary, tt e.y lrave been still sticking on to the stan j, u hich this High Corrrt as rvell as many other High Courts alrea<ly h()ld to be bad. I L It appear s that because of the aforesaid liberti, that trris High Court ha<l tranted permitting the Revenue for initiatilg fresh proceedinlls as a one-time measure in a faceless rnan;re rr, the Income TzL.x I)tpartment wants to take advantage ot.the sarne by protracting tl esr: proceedings which would enable them to rre,et the limitation rhar r,'r,uld otherwise come in the way. I_ikewist, ilthe writ petitior is lept pending for a considerable long periorl rl.time and finally at a ater stage if the Hon,ble Supreme Couft ccnfirms the decisiorr tal:t:r.r by this High Court as also by the othe. High Courts in 'vhicl the SLps are still pending, the Incom,: Tax 9 Department would get the advantage of the liberty that is otherwtse protected in favour of the Revenue for initiation of fresh proceedings from the disposal of these matters at a much later stage which would be advantageous and beneficial to the Revenue and and detrimental so far as interest of the assesses are concerned' As a consequence' the Income Tax Department gets an extended period of time for initiation of fresh would be equally disadvantageous proceedings'

12. The alarming trend of docket explosion in this Court' despite the clear precedent setitt Kanakala Ravindrs Reddy (l supra)' is a matter of grave concern' The Income Tax Department's persistent initiation of fresh proceedings' disregarding the established judicial surge in litigation has led to an unprecedented pronouncements' with over 600-700 petidons piling up ori the same issue' This deliberate approach not only undermines the principle of judicial precedent but also strains the judicial resources unnecessarily' Department's strategy of awaiting the Supreme Court's decision on pending SLPs while continuing to initiate fresh proceedings appears to be a calculated move to buy time and circumvent limitation Wrilds' rather than adhering to the established legal The l t i \ I i I I : i 1 I 1U position. St ch conduct raises serious questiorrs iLtout tbe adminis.ratr,,,: cfficiency and the respe()t ftrr judicial pronouncemen ts, particularly rvhen this Court has alr,:arl) provided a balanced aJ,proach by preserving both the Revenue,s rillhts and assesses interr:sts.

13. Arothi:r :rspect which needs to be considered is that ir fact it should havr, b()en realized by the Income Tax Department t:;elf and should hav,: lound out via media in ensuring rhat proix:edings under Se<:ri<tns l.lg-A and 14g should not have lteen issu:d in a faceless rLanrler. at least till the Hon,ble Supreme Cou.t rft,cide the twelve hundr.ed i i200) odd SLps which it is already seized r lor, at least the inr:onrt: Tax Deparlment should have tbunri ,,rt some remedtal stel)s tr) ensure that wherever the authonties in,le nd to initiate proceedings under Sections l4g_A and I4g,other tlar in a faceless marne'. the proceedings shourd have bee.r dr:l.ened without precipili,t ng the matter further intimating the assess,er: that they shall ilitiatt: appropriate proceedings only after the SLI),s are decided by the J-l:n'ble Supreme Court on the very same i;sue. This again, ihe. Inc:me Tax Department, has not been abl: to rE;ve a ccavincir.g i.erri1, :::.cef' rbr th: fbcl that such a de<;isicn if at all r11 has to be taken, has to be taken for the whole of India' and which otherwise has to be by way of a policy decision and that too at the level of Central Board of Direct Taxes' Though the learned Standing Counsel for the Income Tax Department contended that the Delhi High Court dismissed a writ petition of similar nature' on theonehandwhentheHighCourtisstrugglingtoreduceits pendency, such notices which are under challenge in this writ petition are forcing the assessee to knock the doors of this High Court resulting in fiting of hundreds of new writ petitions which iir the long run not only affects the disposal of the writ petitions but also consumes substantial time of the Bench in hearing these matters again and again on daily basis' Admittedly' in spite of the matterbeforetheHon,blesupremeCourthavingbeentakenon many occasions, the Hon'ble Supreme Court which is seized of the matter has been reluctant in granting any interim protection to the Income Tax Department. Yet, the authorities concerned at the State level are not ready to accept the verdict passed by a majority 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 148-,{ and 12 148 th.u,3rr trre jurisdictionar Assessing off,rcer rvtere,s it ought to have te:n oirly in the faceless manner.

14. In rhr: case of BANK OF INDIA vs. ASI;ISTANT COMM{SSI()NER, INCOME TAXil, on an issue vyhetlrr:r it was justifiable on the part of the Income Tax Dt:parmelt in not followin6l an < rler passed by the adjudicating authonty or 1.,, on the ground thar 1.lrc appeals are pending, the Divisi,:n Ilench of the High Court o1'Bornbay held at paragraph No.25 as under. r ir:.. : "25. Mr. paridwalla has righ y drawn out altention to flre decision of -is Court in Commissioner of lncome Tax,rs. Snrt. Godava.ictovi Sarafl2 as also the recent decision of lhe c,>- ordinete Be tr:h of this Court in Samp Furniture (p) Ltd. v. lTrOr3 of whi;h onr: r:f us (Justice G.S. Kulkarni) was a member, wher 3in the C,)urt calegorically observed that the Revenue havinS, tot "accepted" tlt€r judgment of the High Court would not mear thal till the sarne is ;6;1 ss;6" in a manner known to law, it would loose it; bindingr force,. Referring to the decision of the Supreme Oourt in Union of lnrli,a vs. Kamlakshi Finance Corporation Ltd.ra 116, court.bs;eneJ that the approach of the officiars of Rev€,nue o, treating deci;irtns being ,,not acceptable,, was criticized by fl.re Suprenre Cou t. ln such decision, following are the releva 1l observaticns; made by the Supreme Court. ',) n r n n. c o m 42 2 1 B o m bay ) j 5 t9 1Ben.,6ur,1 " il 9781 I t_? I -R. !A, 23;l .r.', ^o ta.\, ','.720211165 taxn ann.com 5gl/300 Taxman 452 (Bombay) 'o ]t99Z1taxrnanrr. corn I 6/ 55 ELT433 (SC) 13 is perhaps right in saying .that the "6. Sri ReddY not actuated bY anY mala fides in officers were impugned orders. TheY PerhaPs passing the genuinely felt that the claim of the assessee was not tenable and that, if it was accepted' the Revenue would suffer. But what Sri Reddy overlooks is that we are not concerned here with the correctness or otherwise of their conclusion or of any factual malafides but with the fact that the officers' in reaching in their conclusion' by-passed two appellate orders in 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' rightly criticized this conduct of the Assistant Collectors and the harassment to the assessee caused by the failure of these officers to give effect to the orders of authorities higher to them in the appellate hierarchy lt cannot be too vehemently emphasized that it is of utmost importance that, in disposing of the quasijudicial 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 judicial discipline require that the orders of the higher appellate authorities should be followed unreservedly by the subordinate authorities The mere fact that the .acceptable" to order of the appellate authority is not the department - in itself an objectionable phrase - and is the subject matter of an appeal can fumish no ground for not following it unless its operation has been suspended by a competent court- lf this healthy \ "ui. is not foli(,lve(.i. t,:1e i, rrarirssment to assesses rro";;;r' r)f Le x laws. ""1;::J#: 12 \r'/e have dealt witf ) this aspect at som. len lth, boc,a J{ie it has been t"n"tt"o by the learrerJ Addit onar soricitor o"r that the observati.ns; mi)de ly the High n' " been harsh on -he "or,'"t"' oflice -s rt is crear *n", ,t' observations of the High court seemingry ,"rhe and apparenfly unoarr tabre ,o ,n" *"r"rr'"'"nt' le' are only intended to curb .r t3ncency in revenue which' if allowed to tecome widespread, result in considerab e "or'uttu" harass nent to the assesse without any bene,it t. ther Frevenue. we ws-public d,parrn,€nt shourd rake ;::1 [*,:f"Jrl, ,,1] proper spirit. The observ of the High couri sr-ourd t,e kept in mind,n rr,ut'on" shou,d re paid by the r.,r;:::,r";:lillH:::til: ap:e lakr authorities to the disciprin€ of :he hilher appellate auth on th,lln ' rnd the need ;rilT#". orities which are binding ";:::::

15. What is w,)lrying this Bench more is the fact thal an endeavour is berng rnade whole heartedly to ensure not to gen()rtte further litigaticn c,n issues which have been laid to rest b1.a I rrge number of Hi5;h Ccurts all of whom have taken a consiste.rt st,lnd that the action cf.thr: [ncome Tax Deparlment being vio]ative of t,e rb-r..d 15 Finance Act,2O20 and Finance'Act,2\2l' 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 observatior/direction that the disposal ofthe instant writ petition in terms of the judgment rendered by this High Court in the case of Kankanala Ravindra Reddy (1 supra) shalt however be subject to theoutcomeofthesLPswhichwerefiledbythelncomeTax Department and which is pending consideration before the Hon'ble Supreme Court.

16. In the given facts and circumstances' this Bench is of the considered opinion that unless and until we do not timely dispose of matters which are squarely covered by the decision of this Court and which stands fortified by the decisions of the various other High Courts on the very same issue, the pendency of this High Court would further be burdened which otherwise can be decided and disposed of as a covered matter'

17. So far as the interest of the Revenue is concerned' we are of the considered opinion that the interest ofthe Revenue has already been considered and protected, as has been observed in paragraphs 16 36,37 ai .]8 of the order which, for ready reference, is rr:produced hereundr:r :i6. l:or all the aforesaid reasons, the impugned loticr)s ir;su:d and the proceedings drawn by the respc,nderrt. [)epi]rtment is neither tenable, nor sustatnab 3. The n,:tices so issued and the procedure adopted beir.g pel' ,'e, illegal, deserves to be and are accordingly s;)t a,;ide ./quashed. As a consequence, all the impugn€,d ofdels getting quashed, the consequential orders passeJ by lhe respondent-Department pursuant to the notices is:;uel under Section 147 and 14g would also got qt.asfre d and it is ordered accordingly. The reasr,n w ) ar': <; t;rshing the consequential order is on the prin ;iple,; that rvlen the initiation of the proceedings itself r,t,a: proceJLrrally wrong, the subsequent orders also getr. 'ru Irf e d automatically. 37 --h e preliminary objection raised by the petitioner is r;ustairred and all these writ petitions stands alloweC on this verv jurisdictional issue. Since the impugned notices enc cr.iers are getting quashed on the point cf juris;dictir>n, we are not inclined to proceed further and decide the other issues raised by the petitioner wtich slards ,eserved to be raised and contended in an a:p 'op 'i:rte proceedings. 33 ol Ar;his h tiince the Hon'ble Supreme Court had, in the case Agarwal, supra, as a one{ime measure the powers under Article 142 e>:er:isi t1y of ther Con".;titu trrtn of lndia, permitted the Revenue to proceed under Il-€ substituted provisions, and this Court allow ng tho letitrons only on the procedural flaw, the rir;ht r I { I t7 conferred on the Revenue would remain reserved t0 proceed further if they so want from the stage of the order of the Supreme Court in the case of Ashish Agarwal, suPra.

18. We would only fuither like to make observations that since weareinclinedtodisposeoftheinstantwritpetition,consciousof 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 2024' preferred by the Income Tax Department, we make it clear that allowing of the instant writ petition is subject to outcome of the aforesaid SLP preferred by the Revenue against the decision ofthis High Court in the case of Kanakala Ravindra Reddy (1 stpra)' This, in other words, would mean that either of the parties, if they so want, may move an appropriate petition seeking revival of this writ petition in the light of the decision of the Hon'ble Supreme Court in the pending SLP on the very same issue'

19. Accordingly, the instant writ petition stands allowed in favour of the assessee so far as the issue of jurisdiction concemed. As a consequence, the impugned notice under 1S challenge under Sections 148-4 and 148 stands set aside/quashed' i I I ! 18 The conserlu:nl iirl orders, if any, also stand set aside,'quaslLed in similar terrns as have been passed by this High Court in the clse of Kankunala Ruvindra Reddy (l supra). There shall be no (,rrler as to costs. Consecue rlly, miscellaneous petitions pending. if any r;hall stand close,l //TRUE COPY// SD/-P. PIfNNA KRISHNA ASSISTANT IIEGISTRAR r\\ i't SECTI()t\I OFFICER To,

1. Assessment Jrit, ncome Tax Department, National Faceless Asr,;e ssment C;;i* [|"ernrnert of lndia, Jawihadal Nehru lrlarg Blo';k B Pres:; Enclave, Savitri Nagar N,:Yr Delhi - 110002

2. lncome Tax office,r,'iVard 3 1 Hyderabad Room No.727 7ti'-fl:or l:iirJnature - io*"rr Sy N:.fi ti I; )of Kondafur opp Botanical Gardens Serilirgampally M . R.R.Dist. HYclerabrrd

3. The Secretary [Jni,lrt of lndia, Department of Revenue t\'4inistry of Finance North Block t,le'ry tte lhi-'1 1 000 1

4. One CC to S R IV CrHD MUKHAIRUDDIN Advocate toPUCl 5. One CC to N/s. B tll\PNA REDDY SR. SC FOR INCOME: fA ( DEPARTMEI\]T [OPUC] 6 One CC to SRI G,\Dl PRAVEEN KUMAR Dv. SOLICITOR CEN CTF INDIA loPUCl 7 KKS GJP Two CD Copies; 6 HIGH COUR-r DATED:02l1tit2025 -=::=\nr.ei) ( o I c o r) '+ * 13 ,ltu il6 (11 T o/ l"t7.,lt l ORDER WP.No.27399 of 2024 ALLOWING HE WRIT PETITION WITHOUT CO$.rS O)Lr1o %'{-