s steIed soc le v. Union of lndia, Ministry of Finance, ln

Judgment

1. 1 , Sangareddy, lncome Tax Office, erabhadra Nagar, SangareddY -

4. The National Faceless Assessment C of Finance, Government of lndia, N nter, lncome Tax Department, Ministry Delhi - 100 011. ...RESPONDENTS Petition under Article 226 of th'e circumstances stated in the affidavit filed th to issue a writ or direction or order more certiorari calling for the records and qu 11.04.2022 bearing DIN and N 2311042688730(1)for the Assessment 3rdRespondent under Section 148A(d) of t Notice dated 11.04.2022 bearing DIN an 2311042689864(1) for the Assessment 3rdRespondent under Section 148 of the ln quashing the (iii) lmpugned Order dated |TBA/AST/S/1 4712023- 24l1 06378040s( 1 ) nstitution of lndia praying that in the rewith, the High Court may be pleased particularly in the nature of a writ of shing the (i) lmpugned Order dated tice No. ITBA/AST/F/'148A.12022' ear 2018 - 2019, issued bY the e lncome Tax Act, 1961 (ii) lmPugned Notice No. ITBA/AST/S/148 112022' Year 2018 -2019, issued bY the ome Tax Act, 196'1 . and consequentlY 1.O3.2OZ4bearing DIN and Notice No r the Asse.ssment Year 2018 - 2019' issued by the Respondents under Section 147 read with section 144 0f the rncome Tax Act, '1961 as beino i,eg.sl "i"irti"" oii"opf ,.rn," law. and consequen,y set-aside all consequenusub_sequen t noticesloraJl7pena rrres a nd further restra rn the Respondents from making any assessment, reassessment or re-computation or othen'rvise proceeding agarnsi the pertioner on iil"orr,. of rhe aforementioned r mpu gned order and Notice dated t I o q,.ioiz"r' lA NO: 1 oF 2024 z\ .or.zozo ^s1o "i' , "i'trl'

Petition under secti-on 151..CPC praying that in the circumstances stated in the affidavit filed in suonort ot tfre peiltio,n, ill'Hign Court may be pleased to dispense with the firinq oi certified *?,*i rrprgn"o order dated 11 .o4.2o22 bearins DrN and Notice No^. rrer[Iirirasii)iirr-rr,,oo26tl73o(1) Assessmenr year 2018 _ 201.9, i.._r"g ty iil";;; Respondent under Section ror the 148A(d) of the tncome 1?, 19! rsoi tiij lrpri""o Notice dated 11.04.2022 bearins DrN and Notice No rrdeaird)i+#"ddrr-ra,,oor6'e864(.r) ror the Assessment year 2018 - 20'1 9, issued t, il" iia '*"loondent under section 148 0f the lncome Tax Act. tOar,_an{9.9n"*irl",fy qr"."ning the (iii) tmpugned Order dated 31 '03'2024 bearing DrN ,no r'ioti'JJ"'.ruo. rrBA/AST/s/14 7/2023_ 2411063780405(1) for the Assessmeni v"lr""zors -zorg issued by tne Respondents under section r+/iJio'*itn s""l,,oi".,r0 of the rncome tai Act, IA NO: 20 F 2024 Petition under secti_on 151., cPC praying that in the circumstances stated in the affidavit fired in support ot *re peitio'n, ill'r-r'gn court may be preased to suspend a, further Drocg?qirlgs 'pri.rr"t' ,rorgn"d Order dated 31 .03.2024bearinq Dt N,T . Io,(: ri". liiinnili, *r, rorl" _, o n oau ao +oi)1t 7 for the Assess..irt y"r,. 2018._ 2o1s- i.;;; ;; i;; Responoents under Section 147 read with section .144 of i^" Rct, lg6rincruding arl conseq uent/subseq uent notices/orders/p;rritL;; ; the rnrerest of lustice IA NO: 30 F 2024 i"' 'iiu -ir""ri"'"iax Petition under Section r 51 cpc praying that in the circumstances stated in the affidavit fired in suooort or *re petitiJnlii.,Jrir,ii tourt mav oe preased to Jay the operation of rmpuoneci oro* ari"J i i.o"g. zo'z+'o"" ring DIN and Notice No. lTBA/AST/S/14ttzo2SlZ*toa3zso+os1i;"ror"i.,'u"ilru.rr"nt year 2018 _ 201s, issued by the Respondents under s".iit,i iaz'r"rr'*itn section 144 of rherncome all consequent/rror"qrlnt notices/orders/penarties, in the I?J.3;T;J,lli,inctudins I Counsel for the Petitioner: SRI SHEETAL Ms. MYTRI INDUKURU RIKANTH REPRESENTING FOR Counsel for the Respondent Nos.1,2&4: S CENTRAL GOVT I M. VIJAY KUMAR GOUD SC FOR Counsel for the Respondent No.3: SRI Ms INCOME TAX DEPARTMENT . SAPNA REDDY JR SC FOR The Court made the following: ORDER THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOLTRABLE SRI JUSTICE NARSING RAO NANDIKONDA W.P.No.30680 oF 2024 -QBDEB' (per Hon'ble Sri Justice p.Sam Koshy) Heard Mr. Sheetal Srikanth, leanied counsel representing Ms. Mytri Indukuru, learned. counsel for the petitioner and Ms. B.Sapna Reddy, learned Junior Standing Counsel for the Income Tax Department for respondent No.3. perused the record.

2. This is a writ pptition where the proceedings are either challenged to the notices which were issued under Section 14gA and 148 of the Income Tax Act, 196l (for short ,the Act,) or the assessment orders those have been passed under Section 147 of the Act which have been assailed.

3. rrri#p.tition is being taken up today onry on one of rhe grounds, that the notices issued under Section 14gA of the Act and the subsequent initiation of proceedings under Section l4g of the Act by the jurisdictional Assessing Officer, whereas in terms of the amendment that was brought to the Income Tax Act by way of Finance Act, 2021 w.e.f., 01.04.2021 onwards, proceedings 2 1 under Section 148A of the Act as lso under Section 148 of the Act ought to have also been issu and proceeded in a faceless manner

4. The contention of the pet tioner is that the issue of proceedings being in violation of t e Finance Act, 2021 i.e., the impugned notices under Section 14 A and Section 148 of the Act not being issued in a faceless manne , have already been dealt with and decided by this Court in he case of KANKANALA RAVINDRA REDDY vs. INCO E-TAX OFFICERT decided on 14.09.2023 whereby a batch of t petitions were allowed and the proceedings initiated under Secti n 1484, as also under Sectron 148 of the Act were held to be bad th consequential reliefs on the ground of it being in violation of the provisions of Section 151A of the Act read with Notification l8/20 2 dated 29.03.2022. The said judgment passed by this Court has o been subsequently followed in a large ,t-3& of writ petitions hich were allowed on similar terms. 'l(2023) 156 taxmann.com 178 (Tel a)l -,,,

5. Down the line, we find 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 C,MMISSI,NER OF INCOME TAX & OTHERS2, Gauhati High Court in the case of RAM NARAYAN SAH vs..UNION OF INDIAT, punjab and Haryana High Court in the case of JATINDER SINGH BANGU vs. UNION OF INDIA4, and Telangana High Court in the case ol SRI VENKATARAMANAREDDY PATLOOLA I,s. DEPUTY COMMISSIONER OF,INCOME TAX5 where the issue was in respect of intemational taxation, Bombay High Court in the case of ABHIN ANILKUMAR SHAH vs. INCoME TAx OFFICER, INTERNATIONAL TAXATION6 which is again on international taxation and central circle, High Court of Himachal pradesh in the case of GOVIND SINGH vs. INCOME TAX OFFICER?, Gujarat High Court in the case of MANSUKHBHAI ' lzoz+1464 lrR 430 (Bom ' irzozi'1r s6 i;;;,;;;1."# ir, ,o.!fi,, " [(2024) I 65 taxmann.com I I 5 (punjab & Uary ana)] ' [2024) I 67 taxmann.com 4l I (Telangana)] "-l?024) 166 taxmann.com 679 (Bombay)l ' [2024) I 65 taxmaan.co- f f : iHi-u.iJi pradesh)] a a \l ,i \ 4 DAHYABHAI RADADIYA VS. NCOME TAX OFFICER, WARD 3(3X5)8, Jharkand High C urt in the case of SHYAM SUNDAR SAW vs. UNION OF I IAe, Rajasthan High Court in the case of SHARDA DEVI CH AJER vs. INCOME TAX OFFICER & ANOTHER and b ch of writ petitionsro which stood decided on 19.03.2024. Simil r views have also been taken by the Division Bench of Calcu High Court in the case of GIRDHAR GOPAL DALMTA VS. UNION OF INDIA & ORS (M.A.T 1690 of 2023), decided on 2 .09.2024.

6. Even though the same issue ving been decided by a large number of High Courts, we are still onfronted with large filing of identical matters on daily basis ging between 5 to l0 writ petitions. That upon the instructi NS being sought fiom the Department, they have been takin a solitary ground that the decision of the Bombay High Cou in- the case of Heraware Technologies Ltd., (2 supra) as al o the one which has been decided by this Court in the case o Kanakala Ravindra Reddy szoz+ SCC online Guj 4012 '2025 SCC Online Jhar287 72023 : RJ-JD :4984-DB l o ' 5 - (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 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.Courts

7. To a query being put to the learned 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 pendcncy is getting increased on matter which otherwise has already been dealt and decided by this very High Court itself.

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 concemed in the teeth of series of decisions 6 '-'1 by all the major High Courts tn initiating proceedings under Sectio initiating Proceedings under S contravention to the amendments b pursuant to the Finance Act'2020 India are continuouslY still

148.4 of the Act and also tion 148 of the Act tn ught into the Income Tax Act also the Finance Act 2021 ' g. UPon a query being Pufas disposed of in the teeth of the dec the case of Kanakala Rauindra R Counsel for the Income Tax DePa unnecessarilY burden the Inco would be required to file eq Hon'ble SuPreme Court and it exchequer of the Union of India' learned Standing Counsel that no interest olthe petitioners in case i till the finalization of the SL Supreme Court and the fact that the benefit of interim Protection' of this Court as to whY the Inco out with a mechanism to issue why can't this writ Petition be sion rendered bY this Court in dy (1 suPra), learned Standing ment contends that those would Tax DePartment where theY number of SLPs beflore the ould be further burdening the It was also the contention of the rejudice would be caused to the this writ Petition is kePt Pending s pending before the Hon'ble the petitioner is already enjoying Nonetheless, on the earlier query e Tax DePartment have not come propriate instructions or to take 7 appropriate steps in ensuring that proceedings under Section l48A 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 onlybe taken at the level of CBDT 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, u,hat 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 [ncome Tax authorities concemed are still even now in 2025 atso initiating proceedings in contravention to the provisions of Section I5I A ol 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 an issue which otherwise stands squarely col'ered 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 8 insofar as the liberty which was granted to the Revenue for initiating fresh proceedings strictly i accordance with the amended provisions of the Act, as amended y the Finance Act, 2020 and the Finance Act,202l. The petition assessee would be entitled to challenge or raise the other legal obj ions if the Revenue initiates fresh proceedings. The Departm has made no endeavour tn availing the said liberty that was res rved for the Revenue. On the contrary, they have been still sticki g on to the stand, which this High Court as well as mari! other igh Courts already held to be bad. I l. It appears that because ofthe foresaid liberty that this High Court had granted permitting the Revenue for initiating fresh proceedings as a one-time measu in a faceless manner, the Income Tax Department wants to e advantage of the same by protracting these proceedings which uld enable them to meet the limitation that would otherwise com in the way. Likewise, if the writ petition is kept pending for a siderable long period of time and finally at a later stage if the Ho 'ble Supreme Court confirms the decision taken by this High Co as also by the other High Courts in which the SLPs are st ll pending, the Income Tax 9 Department would get the advantage of the liberty that is otherwise protected in favour of the Revenue for initiation of fresh proceedings lrom the disposal of these matters at a much later stage which would be advantageous and beneficial to thc Revenue and would be equally disadvantageous and detrimental s. far as interest of the assesses are concemed. As a consequence, the Income Tax Department gets an extended period of time for initiation of fiesh proceedings

12. The alarming trend of docket explosion in this Court, despite the clear precedent set in Kanakala Ravindra Reddy (L supra), is a matter of grave concern. The Income Tax Department's persistent initiation of fresh proceedings, disregarding the established judicial pronouncements, has led to an unprecedented surge in litigation with over 600-700 petitions piling up on the same issue. This deliberate approach not only undennines the principre of judiciar precedent but also strains the judiciaI resources unnecessarily. The Department's strategy of awaiting the Supreme Court,s decision on ;J:,: ;j "-::.;",' :: : ilffi: :.,::, limitation periods, rather than adhering to the established legal 10 posltlon. Such conduct ralses administrative eff,rciencY and erious questions about the the respect for judicial pronouncements, particularly when is Court has alreadY Provided a balanced aPProach bY Preservtng both the Revenue's rights and assesses interests' i3. Another asPect which needs should have been realized bY the In should have lound out via medi under Sections 148-A and 148 sh faceless manner, at least till the H twelve hundred (1200) odd SLPs least the Income Tax DePartm remedial steps to ensure that w initiate proceedings under Sectio o be considered is that in fact it ome Tax Department itself and in ensuring that Proceedings uld not have been issued in a n'ble SuPreme Court decide the hich it is alreadY seized ofor, at t should have found out some erever the authorities intend to 148-A and 148, other than tn a faceless manner' the Proceedin without PreciPitating the matter they shall initiate appropnate pro decided bY the Hon'ble SuPrem This again, the Income Tax DePa convincing rePlY, excePt for the should have been deferred rther intimating the assessee that edings onlY after the SLP's are Court on the very same lssue ent, has not been able to give a fact that such a decision if at all f 11 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 ol 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 the one hand when the H igh Court is struggling to reduce its pendency, such notices which are under chalenge in this writ petition are forcing the assessee to knock the doors of.this High court resulting in filing ofiundreds of new writ petitions which in the long run not only hffects the disposal of the writ petitions but also consumes substantial time of the Bench in hearing these matters again and again on daity basis. Admittedly, in spite of the matter before the Hon'ble Supreme Court having been taken on many occasions, the Hon'bre Supreme court which is seized of the matter has been reluctant in granting any interim protection to the Income Tax Department. \,et, the authorities concemed 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 continuousry under Sections r4g-A and 12 148 through the jurisdictional Asses ing Officer whereas it ought to have been onlY in the laceless ma er. \

14. In the case of BANK O INDIA VS. ASSISTANT COMMISSIONER,INCOME T t', on an issue whether it was justifiabte on the Part of the Inc me Tax DePartment tn not following an order passed by the adj dicating authoritY onlY on the ground that the aPPeals are Pend High Court of BombaY held at Para , the Division Bench of the ph No.25 as under, viz', : Mr. Paridwalla has rightl "25 decision of this Court in Commissi Godavaridevi Sarafl2 as also th ordinate Bench of this Court in Sa of which one of us (Justice G S KUI the Court categorically observed "accepted" the iudgment of the Hig the same is set aside in a manner binding force. Referring to the de Union of lndia vs. Kamlakshi Fi Court observed that the aPProach treating decisions being "not a ln such decis Supreme Court observations made bY the Suprem drawn out attention to the ner of lncome Tax vs' Smt' recent decision of the co- p Furniture (P) Ltd. v' lTO13 rni) was a member' wherein hat the Revenue having not Court would not mean that till nown to law, it would loose its sion of the SuPreme Court in nce CorPoration Ltd.14, the of the officials of Revenue of ptable" was criticized bY the n, following are the relevant Court. 1202s; 170 taxmann.com422(Bo t' '' iiqzsl I l3 ITR 589 (BombaY) " 1zo2+1165 taxmann.com 581/300 '4 119921 taxmann.com l6155 ELT 43 (SC) v)l axman 452 (BombaY) 13 "6. Sri Reddy is perhaps right in saying that the officers were not actuated by any mala f'ldes in passing the impugned orders. They perhaps 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 lhese officegs 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 offlcers 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 order of the appellate authority is not "acceptable" to the department - in itself an objectionable phrase - and is the subject matter of an appeal can furnish no ground for not followhg it unless its operation has been suspended by a competent court. lf this healthy 74 1 rule is not followed, the re harassment to assesses and ult will only be undue chaos in administration of tax laws

12. We have dealt with this because it has been sug Additional Solicitor General made by the High Court, h officers. lt is clear that the Court, seemingly vehem unpalatable to the Revenue, a tendency in revenue matt become widespread, could harassment to the assesses-p to the Revertue. We woul department should take the proper spirit. The observati should be kept in mind in futur aspect at some length, ed by the learned thaf the observations ve been harsh on the ervations of the High nt, and apparently only intended to curb rs which, if allowed to result in considerable blic without any benefit like to say that the observations in the ns of the High Court and the utmost regard should be paid by the adjudi appellate authorities to the ting authorities and the quirements of judicial discipline and the need for gi ing effect to the orders of the higher appellate autho ties which are binding on them."

15. What is worying this Ben h more is the fact that an endeavour is being made whole he y to ensure not to generate further litigation on issues which h e been laid to rest by a latge number of High Courts all of who have taken a consistent stand that the action of the Income Tax D artment being violative of the 15 Finance Acq2020 and Finance Act,202l. Now, in order to protect the interest of the Revenue as also that of the assessee, it would be trite at this ,iuncture, if we dispose of the writ petition with an observation/d irection 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) shall however be subject to the outcome of the SLPs which were filed by the Income Tax 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 pendencl' 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. rve are of the considered opinion that the interest of the Revenue has already been considered and protected, as has been observed in paragraphs 16 1 36,37 and 38 ofthe order which, for eady reference, is reproduced hereunder:

36. For all the aforesaid rea issued and the proceedings Department is neither te The notices so issued and the per se illegal, deserves to b aside/quashed. As a cgnseq orders getting quashed, the co ns, the impugned notices rawn by the respondent- able, nor sustainable. procedure adopted being and are accordingly sel ence, all the impugned sequenlial orders passed by the respondent-Departmen issued under Seqtio0 147 quashed and it is ordered ac pursuant to the notices d 148 would also get rdingly. The reason we are quashing the consequentia that when the, initiation of th procedurally wrong, the subs order is on the principles proceedings ilself was uent orders also gets nullified automatically.

37. The prelimrnary objection sustained and all these writ p this very jurisdictional issue. Si and orders are getting qu jurisdiction, we are not inclin decide the other issues raise stands reserved to be rais appropriate proceedings. raised by the petitioner is titions stands allowed on ce the impugned notices shed on the point of to proceed further and by the petitioner which and contended in an

38. Since the Hon'ble Supre of Ashish Aqarwal, supra, exercising the powers un Constitution of lndia, permitte e Court had, in the case s a one{ime measure er Article 142 of the the Revenue to proceed under the substituted provisio the petitions only on the p confened on the Revenue , and this Court allowing edural flaw, the right uld remain reserved to L7 proceed furlher if they so want from the stage of the order of the Supreme Courl in the case of Ashlqh Aoarwal, supra.

18. We would only further like to make observations that since we are inclined to dispose of the instant writ petition, conscious o[ the fact that the earlier order of this High Court in the case of Kanakala Ravindra Reddy (1 supra) IS subjected to challenge before the Hon'ble Supreme Court in SLP No.3574 of 2024, t preferred by the Income Tax Department, we make it clear that I allowing of the instant writ petition is subject to outcorne of the aforesaid SLP preferred by the Revenue against the decision of this High Court in the case of Kanakala Ravindra Reddy (l 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 IS concemed. As a consequence, the impugned notice under challenge under Sections 148-A and 148 stands set asider'quashed. 18 I The consequential orders, if any, so stand set aside/quashed in similar terms as have been passed b this High Court in the case of Kankanala Ravindra Reddy (l sup ). -l'here shall be no order as to costs. Consequently, miscellaneous etitions pending, if any, shall stand closed. //TRUE C PYII S /.K.BHAVANI SWAMY ISTANT REGISTRAR SECTION OFFICER

1. Ministry of Finance, Union of lndia, 100 01'1 lncome Tax Department, New Delhi -

2. The Office of Commissioner, lnco Government of lndia New Delhi 10 e Tax Department Ministry of Finance 011

3. Office of the lncome Tax Officer, Veerabhadra Nagar, New Bus Sta 502001

4. The National Faceless Assessmen Ministry of Finance, Government o 5. One CC to lvls. IVYTRI INDUKUR 6. One CC to SRI Ms. B. SAPNA RE DEPARTMENT [OPUC]

7. One CC to SRI M. VIJAY KUMAR ard '1 , Sangareddy, lncome Tax Office, , Veerabhadra Nagar, Sangareddy - Center, lncome Tax Department, lndia, New Delhi - 100 01'1 Advocate tOPUCI DY JR SC FOR INCOIVE TAX OUD SC FOR CENTRAL GOVT loPUCl

8. Two CD Copies €r To, KKS GJP HIGH COURT DATED:2410412025 ORDER WP.No.30680 of 2024 ( a1 va\ M11 AUE ((1 f' ? 1,, { lqrcuec ALLOWING THE WRIT PETITION WITHOUT COSTS P