SHREE VISHVAMURTE TRADINVEST PRIVATE LIMITED THROUGH SAUMIL A. BHAVNAGRI V. INCOME TAX OFFICER, AHMEDABAD

SCA/4370/2022

AI Insights

The case involves multiple writ applications filed by various applicants against the Union of India, concerning notices issued under section 148 of the Income Tax Act. The Supreme Court had recently pronounced a judgment in the case of Union of India vs. Ashish Agarwal, which addressed similar issues and modified the notices issued under the amended section 148 of the IT Act. The High Court of Gujarat, referencing this Supreme Court judgment, decided to dispose of all the writ applications in accordance with the Supreme Court's directions, thereby modifying the earlier High Court judgments and orders.

• Counselvise Citation: [2022] 140 COUNSELVISE.COM (IT) 675936 (HC-GUJARAT)
• Appeal Type: Others
• Pronouncement Date: 05-05-2022
• Assessment Year: misc
• Other Referred Cases: Union of India and others vs. Ashish Agarwal (Civil Appeal No. 3005 of 2022 and allied appeals decided on 4th May 2022)
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: HIGH COURT
• Department Lawyers: DEVANG VYAS
• Assessee Lawyers: TUSHAR HEMANI
• Keywords: High Court; Income Tax; Show cause notice; Special Civil Application; Supreme Court
• Section: 148; 149; 148A

Judgement Text

"C/SCA/1625/2022 ORDER DATED: 05/05/2022 IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/SPECIAL CIVIL APPLICATION NO. 1625 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 19966 of 2021 With R/SPECIAL CIVIL APPLICATION NO. 158 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 264 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 585 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 602 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 606 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 625 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 626 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 627 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 628 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 632 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 645 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 651 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 668 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 670 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 675 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 676 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 678 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 681 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 682 of 2022 With Page 1 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 750 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 758 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 773 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 775 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 795 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 818 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 820 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 828 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 857 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 858 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 863 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 866 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 895 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 898 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 907 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 910 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 911 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 919 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 937 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 946 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 948 of 2022 With Page 2 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 952 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 955 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 983 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1038 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1039 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1040 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1041 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1060 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1062 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1070 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1074 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1076 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1077 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1087 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1088 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1090 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1091 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1093 of 2022 With Page 3 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1094 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1096 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1098 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1100 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1102 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1105 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1106 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1107 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1108 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1130 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1131 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1141 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1142 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1144 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1145 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1189 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1197 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1211 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1216 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1220 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1223 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1226 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1236 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1245 of 2022 With Page 4 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1246 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1270 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1271 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1441 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1510 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1516 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1517 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1570 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1574 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1604 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1647 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1688 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1690 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1733 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1735 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1751 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1760 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1763 of 2022 With Page 5 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1765 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1767 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1775 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1779 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1781 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1784 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1785 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1786 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1789 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1790 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1793 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1816 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1819 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1821 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1852 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1854 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1907 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1950 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1954 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1957 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1958 of 2022 With Page 6 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 1963 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1964 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1968 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1970 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1972 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1974 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1979 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1980 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1985 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1986 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1989 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1990 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1992 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1993 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1994 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1996 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 1999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2002 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2003 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2006 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2007 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2008 of 2022 With Page 7 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2011 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2014 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2015 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2016 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2017 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2020 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2022 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2023 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2024 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2025 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2027 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2028 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2030 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2031 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2032 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2034 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2045 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2048 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2057 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2061 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2064 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2065 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2067 of 2022 With Page 8 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2069 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2072 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2078 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2080 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2081 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2084 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2092 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2097 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2103 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2138 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2142 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2143 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2144 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2184 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2187 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2190 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2194 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2197 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2264 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2266 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2274 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2275 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2276 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2277 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2278 of 2022 With Page 9 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2279 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2280 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2281 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2282 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2283 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2284 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2285 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2286 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2287 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2288 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2289 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2290 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2291 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2292 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2294 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2342 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2349 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2350 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2453 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2464 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2480 of 2022 With Page 10 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 2482 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2484 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2529 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2535 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2539 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2589 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2656 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2657 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2659 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2661 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2664 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2679 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2683 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2684 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2685 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2686 of 2022 With R/SPECIAL 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With R/SPECIAL CIVIL APPLICATION NO. 2988 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2997 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2998 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 2999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3001 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3017 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3019 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3022 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3025 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3027 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3029 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3046 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3048 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3049 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3052 of 2022 With Page 13 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3053 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3054 of 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of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3290 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3296 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3302 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3304 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3306 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3307 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3308 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3310 of 2022 With Page 15 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3312 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3314 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3368 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3382 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3407 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3409 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3417 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3418 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3419 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3424 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3425 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3438 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3444 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3450 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3461 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3463 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3499 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3502 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3515 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3516 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3519 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3523 of 2022 With Page 16 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3525 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3527 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3528 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3529 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3567 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3578 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3587 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3588 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3589 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3590 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3591 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3592 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3593 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3595 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3597 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3598 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3600 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3603 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3606 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3607 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3609 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3611 of 2022 With Page 17 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3612 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3614 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3617 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3619 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3621 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3622 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3627 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3628 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3631 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3632 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3634 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3635 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3636 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3638 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3639 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3641 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3645 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3647 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3652 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3657 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3676 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3728 of 2022 With Page 18 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3755 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3756 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3813 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3826 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3830 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3895 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3910 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3913 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3915 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3918 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3920 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3925 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3940 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3943 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3947 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3948 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3952 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3954 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3956 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3959 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3960 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3961 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3962 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3965 of 2022 With Page 19 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 3967 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3968 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3970 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3971 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3972 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3973 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3975 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3977 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3978 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3979 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3981 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3982 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3991 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 3999 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4000 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4005 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4028 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4029 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4030 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4031 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4035 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4036 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4037 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4059 of 2022 With Page 20 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4100 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4101 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4112 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4114 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4117 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4131 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4201 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4225 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4298 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4300 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4303 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4305 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4306 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4309 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4310 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4314 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4316 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4317 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4318 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4319 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4320 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4330 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4331 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4333 of 2022 With Page 21 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4339 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4341 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4344 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4346 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4350 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4364 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4365 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4366 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4367 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4369 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4370 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4371 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4378 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4380 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4386 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4387 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4388 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4390 of 2022 With Page 22 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4391 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4394 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4454 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4465 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4467 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4470 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4471 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4479 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4534 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4536 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4537 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4538 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4539 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4540 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4546 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4548 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4549 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4550 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4551 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4559 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4571 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4575 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4576 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4577 of 2022 With Page 23 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4578 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4580 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4623 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4624 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4626 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4631 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4633 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4634 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4636 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4637 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4640 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4641 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4644 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4650 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4652 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4654 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4655 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4658 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4659 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4660 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4662 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4667 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4669 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4670 of 2022 With Page 24 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4671 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4672 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4673 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4674 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4742 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4748 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4749 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4751 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4752 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4754 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4755 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4789 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4804 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4808 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4809 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4810 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4811 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4815 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4819 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4836 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4838 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4839 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4848 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4849 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4850 of 2022 With Page 25 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 4853 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4859 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4861 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4867 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4872 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4873 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4875 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4879 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4881 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4882 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4883 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4887 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4891 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4897 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4899 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4926 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4933 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4934 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4935 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4936 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 4938 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5039 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5073 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5075 of 2022 With Page 26 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5111 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5113 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5116 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5152 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5153 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5157 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5159 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5160 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5162 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5164 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5168 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5170 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5174 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5203 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5232 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5233 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5262 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5292 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5309 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5317 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5321 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5326 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5328 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5329 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5331 of 2022 With Page 27 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5332 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5333 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5335 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5336 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5337 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5342 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5343 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5344 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5345 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5347 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5348 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5351 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5352 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5354 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5356 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5358 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5362 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5363 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5365 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5372 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5373 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5377 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5380 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5381 of 2022 With Page 28 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5383 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5384 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5385 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5390 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5391 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5393 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5417 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5420 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5424 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5425 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5426 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5427 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5428 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5429 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5431 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5436 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5459 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5461 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5463 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5466 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5468 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5470 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5472 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5474 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5477 of 2022 With Page 29 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5478 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5481 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5483 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5486 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5489 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5490 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5492 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5494 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5506 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5508 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5510 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5511 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5512 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5582 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5583 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5584 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5586 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5605 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5613 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5663 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5665 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5667 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5677 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5687 of 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of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5826 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5827 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5828 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5830 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5831 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5832 of 2022 With Page 31 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5833 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5834 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5835 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5836 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5837 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5838 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5839 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5840 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5841 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5842 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5843 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5844 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5845 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5846 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5847 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5848 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5850 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5852 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5865 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5869 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5871 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5873 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5879 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5881 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5882 of 2022 With Page 32 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 5884 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5885 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5887 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5888 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 5890 of 2022 With R/SPECIAL CIVIL APPLICATION 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of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7829 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7831 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7994 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 7995 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8009 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8019 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8020 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8021 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8033 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8034 of 2022 With Page 38 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 R/SPECIAL CIVIL APPLICATION NO. 8192 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8233 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8235 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8242 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8244 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8338 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8345 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8346 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8359 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8379 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8386 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8520 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8523 of 2022 With R/SPECIAL CIVIL APPLICATION NO. 8527 of 2022 ========================================================== KANJANI MANOHARLAL BANSILAL HUF THRO MANOHARLAL BANSILAL KANJANI Versus UNION OF INDIA ========================================================== Appearance: F O R T H E R E S P E C T I V E WR I T A P P L I C A N T S I N T H E I R R E S P E C T I V E WR I T A P P L I C A T I O N S : MR . T U S H A R H E MA N I , S E N I O R C O U N S E L WI T H MS . V A I B H A V I P A R I K H ; MR . T I R T H N A Y A K , MR . V I J A Y R A N J A N , D A R S H A N G A N D H I , MR . A V I N A S H P O D D A R , MR . MA N I S H J . S H A H , MR . T E J S H A H , MR . D A R S H A N R . P A T E L , MR . D H I N A L A . S H A H , MR . S . N . D I V A T I A , MS . A R C H A N A A C H A R Y A , MR . B . S . S O P A R K A R , MR . MO H I T B A L A N I , MR . P R I Y A M S H A H , MS . K A MY A MA N I T S H A H , MR . H I R E N J . T R I V E D I , MS . S H R U N J A L T . S H A H , MR . S U D H I R M. ME H T A WI T H MS . S H A I L E E S . ME H T A , MR . H I T E N D R A D . R A J P U T , MS . D I V Y A A G R A WA L , MR . V I J A Y H . P A T E L , MR . J A I MI N A . G A N D H I WI T H MR . S WA P N E S H WA R G O U T A M, MR . U MA I D S I N G H B H A T I , MR . H A R D I K P . MO D H , MR . H A R D I K V . V O R A , MR . D I L I P L . K A N O J I Y A , MR . J E E T J O T A N G I A , MR . Page 39 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 J I MI S . P A T E L , MR . A A D I T R . S A N J A N WA L A , MR . N I R A V P . S H A H , MR . A P U R V A N . ME H T A , MR . R A J S . T A N N A , MR . K E T A N H . S H A H , MR . T A R A K D A MA N I , MR . A D I T Y A A . B I H A N I , MS . N O O P U R K . D A L A L , MR . K U N A L B . G O Y A L , MR . N I MI T Y . S H U K L A , MR . U D I T D . ME H T A , MR . A B H I S H E K M. ME H T A , MR . B . C . T H A K K A R , MR . J A I MI N R . D A V E , MR . P A R V S . G U P T A , MR . N I R A V C . T H A K K A R , MR . S . P . MA J MU D A R , MR . A D I T Y A A . G U P T A , MR . MO H I T A . G U P T A A N D MS . N U P U R D . S H A H , A D V O C A T E S F O R T H E R E S P O N D E N T S - R E V E N U E ( I N C O ME T A X D E P A R T ME N T ) I N T H E I R R E S P E C T I V E WR I T A P P L I C A T I O N S : MR . D E V A N G V Y A S , A D D I T I O N A L S O L I C I T O R G E N E R A L O F I N D I A A P P E A R I N G F O R T H E U N I O N O F I N D I A ; MR . M. R . B H A T T , S E N I O R C O U N S E L WI T H MR . K A R A N S A N G H A N I , L E A R N E D C O U N S E L F O R M R B H A T T & C O . ( 5 9 5 3 ) MR . V A R U N K . P A T E L , S E N I O R S T A N D I N G C O U N S E L ; MS . K A L P A N A K . R A V A L , S E N I O R S T A N D I N G C O U N S E L WI T H MR . N I K U N T K . R A V A L , S T A N D I N G C O U N S E L N O T I C E S E R V E D f o r t h e R e s p o n d e n t ( s ) N o . 1 ========================================================== CORAM:HONOURABLE MR. JUSTICE J.B.PARDIWALA and HONOURABLE MS. JUSTICE NISHA M. THAKORE Date : 05/05/2022 COMMON ORAL ORDER (PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA) 1 We h a v e h e a r d Mr . T u s h a r H e m a n i , t h e l e a r n e d S e n i o r C o u n s e l a s s i s t e d b y Ms . V a i b h a v i P a r i k h ; Mr . T i r t h N a y a k , Mr . V i j a y R a n j a n , D a r s h a n G a n d h i , Mr . A v i n a s h P o d d a r , Mr . Ma n i s h J . S h a h , Mr . T e j S h a h , Mr . D a r s h a n R . P a t e l , Mr . D h i n a l A . S h a h , Mr . S . N . D i v a t i a , Ms . A r c h a n a A c h a r y a , Mr . B . S . S o p a r k a r , Mr . Mo h i t B a l a n i , Mr . P r i y a m S h a h , Ms . K a m y a Ma n i t S h a h , Mr . H i r e n J . T r i v e d i , Ms . S h r u n j a l T . S h a h , Mr . S u d h i r M. Me h t a w i t h Ms . S h a i l e e S . Me h t a , Mr . H i t e n d r a D . R a j p u t , Ms . D i v y a A g r a w a l , Mr . V i j a y H . P a t e l , Mr . J a i m i n A . G a n d h i w i t h Mr . S w a p n e s h w a r G o u t a m , Mr . U m a i d s i n g h B h a t i , Mr . H a r d i k P . Mo d h , Mr . H a r d i k V . V o r a , Mr . D i l i p L . K a n o j i y a , Mr . J e e t J o t a n g i a , Mr . J i m i S . Page 40 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 P a t e l , Mr . A a d i t R . S a n j a n w a l a , Mr . N i r a v P . S h a h , Mr . A p u r v a N . Me h t a , Mr . R a j S . T a n n a , Mr . K e t a n H . S h a h , Mr . T a r a k D a m a n i , Mr . A d i t y a A . B i h a n i , Ms . N o o p u r K . D a l a l , Mr . K u n a l B . G o y a l , Mr . N i m i t Y . S h u k l a , Mr . U d i t D . Me h t a , Mr . A b h i s h e k M. Me h t a , Mr . B . C . T h a k k a r , Mr . J a i m i n R . D a v e , Mr . P a r v S . G u p t a , Mr . N i r a v C . T h a k k a r , Mr . S . P . Ma j m u d a r , Mr . A d i t y a A . G u p t a , Mr . Mo h i t A . G u p t a a n d Ms . N u p u r D . S h a h , t h e l e a r n e d c o u n s e l a p p e a r i n g f o r t h e r e s p e c t i v e w r i t a p p l i c a n t s i n t h e i r r e s p e c t i v e w r i t a p p l i c a t i o n s a n d Mr . D e v a n g V y a s , t h e l e a r n e d A d d i t i o n a l S o l i c i t o r G e n e r a l o f I n d i a a p p e a r i n g f o r t h e U n i o n o f I n d i a ; Mr . M. R . B h a t t , t h e l e a r n e d S e n i o r C o u n s e l a s s i s t e d b y Mr . K a r a n S a n g h a n i , t h e l e a r n e d c o u n s e l ; Mr . V a r u n K . P a t e l , t h e l e a r n e d S e n i o r S t a n d i n g C o u n s e l ; Ms . K a l p a n a K . R a v a l , t h e l e a r n e d S e n i o r S t a n d i n g C o u n s e l w i t h Mr . N i k u n t K . R a v a l , t h e l e a r n e d S t a n d i n g C o u n s e l a p p e a r i n g f o r t h e r e s p o n d e n t s - R e v e n u e ( I n c o m e T a x D e p a r t m e n t ) i n t h e i r r e s p e c t i v e w r i t a p p l i c a t i o n s . 2 A l l t h e c a p t i o n e d w r i t a p p l i c a t i o n s a r e o r d e r e d t o b e d i s p o s e d o f i n v i e w o f t h e r e c e n t p r o n o u n c e m e n t o f t h e S u p r e m e C o u r t i n t h e c a s e o f U n i o n o f I n d i a a n d o t h e r s v s . A s h i s h A g a r w a l ( C i v i l A p p e a l N o . 3 0 0 5 o f 2 0 2 2 a n d a l l i e d a p p e a l s d e c i d e d o n 4 t h Ma y 2 0 2 2 ) . We q u o t e t h e r e l e v a n t o b s e r v a t i o n s m a d e b y t h e S u p r e m e C o u r t a s u n d e r : “ 1 0 . I n v i e w o f t h e a b o v e a n d f o r t h e r e a s o n s s t a t e d a b o v e , t h e p r e s e n t A p p e a l s a r e A L L O WE D I N P A R T . T h e i m p u g n e d c o m m o n j u d g m e n t s a n d o r d e r s p a s s e d b y t h e H i g h C o u r t o f J u d i c a t u r e a t A l l a h a b a d i n W. T . N o . 5 2 4 / 2 0 2 1 a n d o t h e r a l l i e d t a x a p p e a l s / p e t i t i o n s , i s / a r e h e r e b y m o d i f i e d a n d s u b s t i t u t e d a s u n d e r : - ( i ) T h e i m p u g n e d s e c t i o n 1 4 8 n o t i c e s i s s u e d t o t h e r e s p e c t i v e a s s e s s e e s w h i c h w e r e i s s u e d u n d e r u n a m e n d e d s e c t i o n 1 4 8 o f t h e I T A c t , w h i c h w e r e t h e s u b j e c t m a t t e r o f w r i t p e t i t i o n s b e f o r e t h e v a r i o u s r e s p e c t i v e H i g h C o u r t s s h a l l b e d e e m e d t o h a v e b e e n i s s u e d u n d e r s e c t i o n 1 4 8 A o f t h e I T A c t a s s u b s t i t u t e d b y t h e F i n a n c e A c t , 2 0 2 1 a n d c o n s t r u e d o r t r e a t e d t o b e s h o w - c a u s e n o t i c e s i n t e r m s o f s e c t i o n Page 41 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 1 4 8 A ( b ) . T h e a s s e s s i n g o f f i c e r s h a l l , w i t h i n t h i r t y d a y s f r o m t o d a y p r o v i d e t o t h e r e s p e c t i v e a s s e s s e e s i n f o r m a t i o n a n d m a t e r i a l r e l i e d u p o n b y t h e R e v e n u e , s o t h a t t h e a s s e s e e s c a n r e p l y t o t h e s h o w - c a u s e n o t i c e s w i t h i n t w o w e e k s t h e r e a f t e r ; ( i i ) T h e r e q u i r e m e n t o f c o n d u c t i n g a n y e n q u i r y , i f r e q u i r e d , w i t h t h e p r i o r a p p r o v a l o f s p e c i f i e d a u t h o r i t y u n d e r s e c t i o n 1 4 8 A ( a ) i s h e r e b y d i s p e n s e d w i t h a s a o n e - t i m e m e a s u r e v i s - a - v i s t h o s e n o t i c e s w h i c h h a v e b e e n i s s u e d u n d e r s e c t i o n 1 4 8 o f t h e u n a m e n d e d A c t f r o m 0 1 . 0 4 . 2 0 2 1 t i l l d a t e , i n c l u d i n g t h o s e w h i c h h a v e b e e n q u a s h e d b y t h e H i g h C o u r t s . E v e n o t h e r w i s e a s o b s e r v e d h e r e i n a b o v e h o l d i n g a n y e n q u i r y w i t h t h e p r i o r a p p r o v a l o f s p e c i f i e d a u t h o r i t y i s n o t m a n d a t o r y b u t i t i s f o r t h e c o n c e r n e d A s s e s s i n g O f f i c e r s t o h o l d a n y e n q u i r y , i f r e q u i r e d ; ( i i i ) T h e a s s e s s i n g o f f i c e r s s h a l l t h e r e a f t e r p a s s o r d e r s i n t e r m s o f s e c t i o n 1 4 8 A ( d ) i n r e s p e c t o f e a c h o f t h e c o n c e r n e d a s s e s s e e s ; T h e r e a f t e r a f t e r f o l l o w i n g t h e p r o c e d u r e a s r e q u i r e d u n d e r s e c t i o n 1 4 8 A m a y i s s u e n o t i c e u n d e r s e c t i o n 1 4 8 ( a s s u b s t i t u t e d ) ; ( i v ) A l l d e f e n c e s w h i c h m a y b e a v a i l a b l e t o t h e a s s e s s e s i n c l u d i n g t h o s e a v a i l a b l e u n d e r s e c t i o n 1 4 9 o f t h e I T A c t a n d a l l r i g h t s a n d c o n t e n t i o n s w h i c h m a y b e a v a i l a b l e t o t h e c o n c e r n e d a s s e s s e e s a n d R e v e n u e u n d e r t h e F i n a n c e A c t , 2 0 2 1 a n d i n l a w s h a l l c o n t i n u e t o b e a v a i l a b l e . 1 1 . T h e p r e s e n t o r d e r s h a l l b e a p p l i c a b l e P A N I N D I A a n d a l l j u d g m e n t s a n d o r d e r s p a s s e d b y d i f f e r e n t H i g h C o u r t s o n t h e i s s u e a n d u n d e r w h i c h s i m i l a r n o t i c e s w h i c h w e r e i s s u e d a f t e r 0 1 . 0 4 . 2 0 2 1 i s s u e d u n d e r s e c t i o n 1 4 8 o f t h e A c t a r e s e t a s i d e a n d s h a l l b e g o v e r n e d b y t h e p r e s e n t o r d e r a n d s h a l l s t a n d m o d i f i e d t o t h e a f o r e s a i d e x t e n t . T h e p r e s e n t o r d e r i s p a s s e d i n e x e r c i s e o f p o w e r s u n d e r A r t i c l e 1 4 2 o f t h e C o n s t i t u t i o n o f I n d i a s o a s t o a v o i d a n y f u r t h e r a p p e a l s b y t h e R e v e n u e o n t h e v e r y i s s u e b y c h a l l e n g i n g s i m i l a r j u d g m e n t s a n d o r d e r s , w i t h a v i e w n o t t o b u r d e n t h i s C o u r t w i t h a p p r o x i m a t e l y 9 0 0 0 a p p e a l s . We a l s o o b s e r v e t h a t p r e s e n t o r d e r s h a l l a l s o g o v e r n t h e p e n d i n g w r i t p e t i t i o n s , p e n d i n g b e f o r e v a r i o u s H i g h C o u r t s i n w h i c h s i m i l a r n o t i c e s u n d e r S e c t i o n 1 4 8 o f t h e A c t i s s u e d a f t e r 0 1 . 0 4 . 2 0 2 1 a r e u n d e r c h a l l e n g e . 1 2 . T h e i m p u g n e d c o m m o n j u d g m e n t s a n d o r d e r s p a s s e d b y t h e H i g h C o u r t o f A l l a h a b a d a n d t h e s i m i l a r j u d g m e n t s a n d o r d e r s p a s s e d b y v a r i o u s H i g h C o u r t s , m o r e p a r t i c u l a r l y , t h e r e s p e c t i v e j u d g m e n t s a n d o r d e r s p a s s e d b y t h e v a r i o u s H i g h C o u r t s p a r t i c u l a r s o f w h i c h a r e Page 42 of 43 C/SCA/1625/2022 ORDER DATED: 05/05/2022 m e n t i o n e d h e r e i n a b o v e , s h a l l s t a n d m o d i f i e d / s u b s t i t u t e d t o t h e a f o r e s a i d e x t e n t o n l y . A l l t h e s e a p p e a l s a r e a c c o r d i n g l y p a r t l y a l l o w e d t o t h e a f o r e s a i d e x t e n t . I n t h e f a c t s o f t h e c a s e , t h e r e s h a l l b e n o o r d e r a s t o c o s t s . ” 3 I n v i e w o f t h e a f o r e s a i d , a l l t h e w r i t a p p l i c a t i o n s s t a n d d i s p o s e d o f i n t e r m s o f t h e a f o r e s a i d o r d e r p a s s e d b y t h e S u p r e m e C o u r t . 4 We c l a r i f y t h a t i n a n y p a r t i c u l a r m a t t e r i f t h e r e i s a n y o t h e r i s s u e o t h e r t h a n S e c t i o n 1 4 8 o f t h e I n c o m e T a x A c t , 1 9 6 1 , t h e n w e r e s e r v e t h e l i b e r t y i n f a v o u r o f t h a t p a r t i c u l a r w r i t a p p l i c a n t t o f i l e a f r e s h w r i t a p p l i c a t i o n i n a c c o r d a n c e w i t h l a w . (J. B. PARDIWALA, J) (NISHA M. THAKORE,J) CHANDRESH Page 43 of 43 "