Tecumseh Products India Private Limited V. The Deputy Commissioner of Income Tax, Circle-2(1) and The Chief Commissioner of Income Tax II and The Union of India, through the Secretary, Ministry of Finance

WP/33806/2024

AI Insights

The case involves Tecumseh Products India Private Limited challenging notices and orders issued by the Income Tax Department under Sections 148 and 148A of the Income Tax Act, 1961, for reassessment proceedings for the assessment year 2018-19. The petitioner argued that these proceedings were not conducted in a faceless manner as required by recent amendments to the Act. The High Court examined similar cases and precedents where it was held that such proceedings should be faceless, leading to the quashing of the impugned notices and orders. The court noted the increasing backlog of similar cases and the Department's failure to adhere to judicial precedents, emphasizing the need for timely judicial intervention to prevent further litigation.

• Counselvise Citation: [2025] 140 COUNSELVISE.COM (IT) 683627 (HC-TELANGANA)
• Appeal Type: Others
• Pronouncement Date: 24-04-2025
• Assessment Year: misc
• Other Referred Cases: Kankanala Ravindra Reddy vs. Income-Tax Officer, Hexaware Technologies Ltd. vs. Assistant Commissioner of Income Tax & Others, RAM NARAYAN SAI vs. UNION OF INDIA, JATINDER SINGH BANGU vs. UNION OF INDIA, SRI VENKATARAMANA REDDY PATLOOLA VS. DEPUTY COMMISSIONER OF INCOME TAX, ABHIN ANILKUMAR SHAH vs. INCOME TAX OFFICER, INTERNATIONAL TAXATION, GOVIND SINGH vs. INCOME TAX OFFICER, MANSUKHBHAI vs. INCOME TAX OFFICER, SHYAM SUNDAR SAW vs. UNION OF INDIA, SHARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER, GIRDHAR GOPAL DALMIA vs. UNION OF INDIA & ORS, BANK OF INDIA VS. ASSISTANT COMMISSIONER, INCOME TAX, Commissioner of Income Tax vs. Smt. Godavaridevi Saraf, Samp Furniture (P) Ltd. v. ITO, Union of India vs. Kamlakshi Finance Corporation Ltd.
• Laws Referred To: Income Tax Act, 1961, Finance Act, 2020, Finance Act, 2021
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: B SAPNA REDDY; CADI PRAVEEN KUMAR
• Assessee Lawyers: HARPREET SINGH AJMANI
• Keywords: Faceless Proceedings; Income Tax; Mandamus; Reassessment; Writ petition
• Section: 147; 148; 151; 148A; 226

Judgement Text

"i 13447 ) HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) THURSDAY, THE TWENTY FOURTH DAY OF APRIL TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY ANO THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA Between: Tecumseh Products lndia Private Limited, Survey No. 6671P And 7B4lP, Medchal S.O., Kistapur, K.V. Rangareddy 501401, Telangana, lndia, Rep. by its CFO, Ms. Ruchi Babbar .,.PETITIONER AND 1 The Deputy Commissioner of lncome Tax, Circle-2( l), Room No. 514, sth Floor, Signatures Tower, Hyderabad, Telangana. The Chief Commissioner of lncome Tax ll, Seventh Floor, A Block, lncome Tax Towers, AC Guards, Masab Tank Hyderabad 3. The Union of lndia, through the Secretary, Ministry of Finance, Government of lndia, North Block, New Delhi ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated. in the affidavit filed therewith, the High Court may be pleased to issue an appropriate Writ, Order or Direction more particu la rly in the nature of MANDAMUS under article 226 of lhe Constitution of lndia, directing that (a) The lmpugned Order dated 2710812024 passed under section 14BA(d) of the lT Act may be quashed by holding the same as arbitrary, illegal and void. and (b) The lmpugned Notice dated 2710812024 passed under section 148 of the lT Act thereby initiating the reassessment proceedings for AY 2O1B-19 may be quashed by holding the same as arbitrary, illegal and void. a .t I WRIT PETITION NO: 33806 OF 2024 I lA NO: 1 OF 2024 Petition under Section 151 CPC praying that in the circumstances stated in the affidavit filed rn support of the petition, the High Court may be pleased to grant stay all further proceedings pursuant to the impugned Order passed under section 14BA (d) of the lncome Tax Act, 1961, r.w. the impugned notice issued under section 148 of the lT Act, both dated2T-08-2024,by1he First Respondent pending disposal of the above Wrrt Petition. Counsel for the Petitioner: SRI HARPREET SINGH AJMANI, REPRESENTING SRI G. NARENDRA CHETTY Counsel for the Respondent Nos.1 and 2: MS. B. SAPNA REDDY, BoKARO SAPNA REDDY (Jr. Sc FOR INCOME TAX) Counsel for the Respondent No.3: SRI cADl PRAVEEN KUMAR, DEPUTY SOLICITOR GENEAL OF INDIA The Court made the following: ORDER H !. i: i. :t /r) THE HONOT]RABLE SRI JUSTrcE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA WRIT PETITIONNo.33806 of2024 QRDEB, @er Hon'ble Sri Justice P.Sam Koshy) Heard Mr. Harpreet Singh Ajmani, leamed counsel representing Mr.G.Narendra Chetty, leamed counsel for the petitioner and Ms. B.Sapna Reddy, leamed Junior Standing Counsel for the lncome Tax Department for respondent Nos'l and 2. Perused the record. 2. This is a writ petition where the proceedings are either challenged to the notices which were issued under Section l48A 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. This writ petition is being taken up today only on one of the grounds, that the notices issued under Section l48A of the Act and the subsequent initiation of proceedings under Section 148 of the Act by the jurisdictional Assessing Officer' whereas in terms of the amendment that *u, Uirlf,t to the Income Tax Act by way Page 2 of 18 of Finance Act. 202 I w.e.f., 01.04.2021 onwards, proceedings under Section l48A of the Act as also under Section l4g of the Act ought to have also been issued and proceeded in a faceless I manner. 4. The contention of the petitioner is that the issue of proceedings being in violation of the Finance Act, 2021 i.e., the impugned notices under Section l4gA and Section l4g of the Act not being issued in a faceless manner, have already been dealt with and decided by this Court in the case of KANKANALA RAVINDRA REDDY vs. INCOME_TAX OFFICERT decided on 14.09.2023 whereby a batch of writ petitions were allowed and the proceedings initiated under Section l4gA as also under Section 148 of the Acr wcre hcld to be bad with consequential reliefs on the ground of it being in vioration of the provisions of Section r5rA of the Act read with Notification lg/2022 dated29.03.2022. The said judgment passed by this Court has also been subsequently followed in a large nunrber of writ petitions which were allowed on similar terms '[(2023) 156 rarnranrr.com I 78 ('felangana)] Page 3 of 18 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 COMMISSIONER OF INCOME TAX & OTHERS2, Gauhati High Court in the case of RAM NARAYAN SAII 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 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 OFFICER' INTERNATIONAL TAXATION6 which is again on intemational taxation and central circle, High Court of Himachal Pradesh in the case ol GOVIND SINGH vs. INCOME TAX OFFICER?, Gujarat High Court in the case of MANSUKHBHAI '7zoz11464 ITR 430 (Bom) '[(2024) 156 taxmann.com 478 (Gauhati)] ^ [(2024) 165 taxmann.com 1 l5 (Pt4iab & I{aryana)] ' [2024) 167 taxmann.com 4l i (Telangana).1 ' [2024) 166 taxmann.com 679 (Bombay)] '[2024) 165 taxmann.com I 13 (Himachal Pradesh)] Page 4 of 18 DAHYABHAI RADADIYA vs. INCOME TAX OFFICER, WARD 3(3X5)6, Jharkand High Court in the case of SHYAM SUNDAR SAW vs. UNION OF lNDIAe, Rajasthan High Court in the case ol SI{ARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER and batch of writ petitionsro which stood decided on 19.03.2024. Similar views have also been taken by the Division Bench of Calcutta High Court in the case of GIRDHAR (;OPAL DALMIA vs. IINION OF INDIA & ORS (M.A.T 1690 o12023), decided on25.09.2024. 6. Even though the same issue having been decided by a large number of High Courts. we are still confronted with large filing of identical nratlers on daily basis ranging between 5 to l0 writ petitions. That upon the instructions being sought fi'om the Department, the1, have been taking a solitary ground that the decision of thc Bornbay High Court in the case ol' Hexaware Technologies Ltd., (2 supra) as also the one which has been decided b1 this Court in the case of Kanakala Ravindro Reddy '202+ SCC onl.ine Gu.i 4012 \"2025 SCC Onl.ine Jhar 287 'o 12023, RJ-JD:4984-t)B I i .,/,-t Page 5 of 18 (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 of the 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 pendency is getting increased on matter which otherwise has already been dealt and decided by this very High Court irself. 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 ['age 6 of 18 by all the rna.ior High Courts in India are continuously still initiating proceedings under Section l48A of the Act and also initiating proceedings under Section I48 of the Act in contravention to the amendments brought into the Income Tax Act pursuant to the Finance Act,2020 as also the Finance Act 2021. 9. Upon a query being put as to why can't this writ petition be disposed of in the teeth of the decision rendered by this Court in the case of Kanakala Ravindru Reddy (l supra), learned Standing Counsel for the Income Tax Department contends that those would unnecessarily burden the Income Tax Departrnent rvhere they would be required to file equal number of SLPs before the Hon'ble Supreme Court and it would be further burdening the exchequer of the Union of India. It was also the contention of the leamed Standing Counsel that no prejudice rvould be caused to the interest of the petitioners in case if this writ petition is kept pending till the finalization ol the SLPs pending before the Hon'ble Supreme Court and the fact that the petitioner is already enjoying the benefit of interim protection. Nonetheless, on the earlier query of this Court as to why the Income Tax Department have not come I out with a rnechanism to issue appropriate instruftio-hs or to take Pagc 7 of 18 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 of the 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 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, 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 l5l A 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 an issue which otherwise stands squarely covered by the judgment of this Court in the case of Kanakala Rovindra 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 'a Page 8 of 18 insofar as the liberty which was granted to the Revenue for initiating fresh proceedings strictly in accordance with the amended provisions of the Act, as amended by the Finance Act, 2020 and the Finance Act,202l. The petitioner assessee would be entitled to challenge or raise the other legal objections if the Revenue initiates fresh proceedings. The Department has made no endeavour in availing the said liberty that was reserved for the Revenue. On the contrary, they have been still sticking on ro the stand, which this High Court as u,ell as many other High Courts alreadv held to be I l. It appears that because of the aforesaid liberry that this High Court had granted permitting the Revenue for initiating fresh proceedings as a one-time measure in a faceless manner, the Income Tax Depaftment wants to take advantage of the same by protracting these proceedings which would enable them to meet the limitation that would otherwise come in the way. Likewise, if the writ petition is kept pending for a considerable long period of time and finally at a later stage if the Hon'ble Supreme Court confirms the decision taken by this High Court as also by the other High Courts in which the SLPs are still pending, the Income Tax , l bad - I l'age I ot la Department would get the advantage of the tiberty that is otherwise protected in favour of the Revenue for initiation of fresh proceedings from the disposal ofthese matters at a much later stage which would be advantageous and beneficial to the Revenue and would be equally disadvantageous and detrimcntal so far as interest of the assesses are concemed. As a consequence, the Income Tax Department gets an extended period of time for initiation of fresh proceedings. 12. The alarming trend of docket explosion in this Court, despite the clear precedent sel in Kanoktla Rovindra 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 undermines the principle of judicial precedent but also strains the judicial resources unnecessarily. The Department's strategy of awaiting the Suprerne Court's decision on pending SLPs while continuing to initiate fresh proceedings appears to be a calculated move to buy time and circumvent limitation periods, rather than adhering to the established legal I Page 10 of 18 position. Such conduct raises serious questions about the administrative efficiency and the respect for judicial pronouncements. particularly when this Court has already provided a balanced approach by preserving both the Revenue's rights and assesses interests. 13. Another aspect which needs to be considered is that in fact it should have been realized by the Income Tax Department itself and should have found out via media in ensuring that proceedings under Sections 148-A and 148 should not have been issued in a faceless manner, at least till the Hon'ble Supreme Coun decide the twelve hundred (1200) odd SLps which it is already seized of or, at least the lncome Tax Department should have found out some remedial steps to ensure that wherever the authorities intend to initiate proceedings under Sections 148-A and 148, other than in a faceless manher, the proceedings should have been deferred without precipitating the matter further intimating the assessee that they shall initiate appropriate proceedings only after the SLp's are decided by the l{on'ble Supreme Court on the very same issue. This again, the Income Tax Department, has not been able to give a convincing reply, except for the fact that such a decision if at all ! Page 11 of 18 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 leamed 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 High Court is struggling to reduce its 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 filing of hundreds of new writ petitions which in 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 matter before the Hon'ble Supreme Court having been taken on 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 concemed at the State level are not ready to accept the verdict passed by a maj ority of High Courts of different States on the same issue; and to make ) things further wor'se, the Income Tax Department is showing audacity by issuing notices continuously under Sections 148-A and Page 12 of 18 148 through the jurisdictional Assessing Officer whereas it ought to have been onlv in the faceless manner. 14. ln the case of BANK OF INDIA VS. ASSISTANT COMMISSIONER, INCOME TAXrr, on an issue whether it was justifiable on the part of the Income Tax Department in not lotlowing an order passed by the adjudicating authority only on the ground that the appeals are pending, the Division Bench of the High Court of Bombay held at paragraph No.25 as under, viz., : \"25 filr. Paridwalla has rightly drawn out attention to the decision of this Court in Commissioner of lncome Tax vs. Smt. Godavaridevi Sarafl2 as also the recent decision of the co- ordinate Bench of this Court in Samp Furniture (P) Ltd. v. ITO'3 of which one of us (Justice G.S. Kulkarni) was a member, wherein the Court categorically observed that the Revenue having not \"accepted\" the ludgment of the High Court would not mean that till the same is set aside in a manner known to law, it would loose its bindang force. Referring to the decision of the Supreme Court in Union of lndia vs. Kamlakshi Finance Corporation Ltd.r4, the Court observed that the approach of the officials of Revenue of treating decisions being \"not acceptable\" was criticized by the Supreme Court. ln such decision, following are the relevant observations made by the Supreme Court, ./ ' I 11202s ) I 70 laxmann.com 422 ( Bombay)l / '' 119281 I t3 It'R 589 (Bombay) \" TZOZ+1 [65 taxmann.com 581/300 Taxman 452 (Bombay) t'ltggzl taxnrann.com l6155 ELT 433 (SC) ,, a._ I I r \"6. Sri Reddy officers were 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 lo 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 requare 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 fumish no ground for not following it unless its operation has been suspended by a competent court lf this healthy Page 13 of 18 is perhaps right in saying not actuated bY anY mala impugned orders. TheY that the fides in perhaps Page 14 of 18 rule is not followed, the result will only be undue harassment to assesses and chaos in administration of tax laws. 12 We have dealt with this aspect at some length, because it has been suggested by the learned Additional Solicitor General that the observations made by the High Court, have been harsh on the officers. lt is clear that the observations of the High Court, seemingly vehement, and apparently unpalatable to the Revenue, are only intended to curb a tendency in revenue matters which, if allowed to become widespread, could result in considerable harassment to the assesses-public without any benefit to the Revenue. We would like to say that the department should take these observations in the proper spirit. The observations of the High Court should be kept in mind in future and the utmost regard should be paid by the adjudicating authorities and the appellate authorities to the requirements of judicial discipline and the need for giving effect to the orders of the higher appellate authorities which are binding on thern.\" 15. What is woffying this Bench more is the fact that an endeavour is being made whole heartedly to ensure nor to generate Iurther titigation on issues which have been laid to rest by a large number ol ttigh Courts all of whom have taken a consistent stand that the action ol-the Income Tax Department being violative of the .i '{ Page 15 of 18 Finance Ac|,2020 and Finance Act, 2021 - Now, in order to protect the interest of the Revenue as also that of the assessee' it would be trite at this juncture, if we dispose of the writ petition with an observation / direction that the disposal of the instant writ petition in terms of the judgment rendered by this High Court in the case of Kankanala Ravindra Reddy (l 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. tn 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 ofas a covered matter. 17 . So far as the interest of the Revenue is concemed, we are of the considered opinion that the interest of the Revenue has already been considered and protected, as has been observed in paragraphs I I I Page 15 of 18 36, 37 and 18 o1' the order which, for ready reference, is reproduced hereunder 36 For all the aforesaid reasons, lhe impugned notices issued and the proceedings drawn by the respondent- Department is neither tenable, nor sustainable. The notices so issued and the procedure adopted being per se illegal, deserves to be and are accordingly set aside/quashed. As a consequence, all the impugned orders getting quashed, lhe consequential orders passed by the respondent-Department pursuant to the notices issued under Section 147 and 148 would also get quashed and it is ordered accordingly. The reason we are quashing the consequential order is on the principles that when the initiation of the proceedings itself was procedurally wrong, the subsequent orders also gets nullified automatically. 37. The preliminary objection raised by the petitioner is sustained and all these writ petitions stands allowed on this very Jurisdictional issue. Since the impugned notices and orders are getting quashed on the point of Jurrscjrction. we are not inclined to proceed further and decide the other issues raised by the petitioner which stands reserved to be raised and contended in an appropriate proceedings. 38. Since the Hon'ble Supreme Court had, in the case of Ashish Agarwal, supra, as a one-time measure exercising the powers under Article 142 of the Constitution of lndia, permitted the Revenue to proceed under the substituted provisions, and this Court allowing the petitions only on the procedural flaw, the right a .l { Page 17 of 18 conferred on the Revenue would remain reserved to proceed further if they so want from the stage of the order of the Supreme Court in the case of Ashish Agarwal, supra. 18. We would only further like to make observations that since we are inclined to dispose of the instant writ petition, conscious of the fact that the earlier order of this High Court in the case of Kanakala Ravindra Reddy (I 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 of this High Court in the case of Ksnakala Ravindra Reddy (1 supra). 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. favour of the assessee so far as the issue of jurisdiction 1S concerred. As a consequence, the impugned notice under challenge under Sections 148-4 and 148 stands set aside/quashed. 19. Accordingly, the instant writ petition stands allowed in Page 18 of 18 The consequential orders' if any' also stand set aside/quashed in similar terms as have been passed by this High Court in the case of Kankanala Ruvindra Reddy (l supra)' There shall be no order as tO COSTS I Consequently, miscellaneous petitions pending' if any' shall stand closed //TRUE COPY// The DePutY Com missioner of Income Tax, Circle ). Room No 5'14' 5th Floor, Signatures Tower, H bad, Telan A Block' lncome ydera f lncome Tax ll' oana. Seventh Floor' 2. The Chief Tax Towe rs, AC Com missioner o Guards, Masab Tank HYd The Union oi lndia, Ministry erabad of Finance' Government of lndia' he Secreta orth Block, ry. New Delhi To, 1 eT 4. The Chief Comm issioner of lncome Tax-ll, Seventh Floor, A Block, lncome N Tax Towers, AC Guards, Masab Tank HYdetabad 500004 , Telang overnme ana nt of lndia, 5. The SecretarY, The Union of lndia. Ministry of Finance, G NorthBlock. New Delhi 1 10 101 One Cc to sri b Narendra ChettY, Advocate [OPUC] Tax) [oPUcl One One CC to Sri CC to Sri Bokaro SaP Gadi Pravee na ReddY (Jr. SC DePutY for lncome Solicitor General of lndialoPUCl 6 7 8 I TJ KV n Kumar' Two CD CoPies W 1'. i' [, ..i 3?i;,hiE3't+RlR SiECTION OFFICER I I i: F t i I I t i u l; :l HIGH COURT DATED:2410412025 ORDER WP.No.33806 of 2024 ALLOWING THE WRIT PETITION WITHOUT COSTS (. : 2 I tiiAl ?0tE C. i Y E r€ S1A c J ii6ar. ,'!f fM +{ "