Primary Agriculture Co-Operative Society Limited V. The Assistant Commissioner of Income Tax Circle 1

WP/25417/2024

AI Insights

The case involves multiple writ petitions filed by various petitioners, including cooperative societies and individuals, against the Income Tax Department and other governmental bodies. The petitions challenged the assessments made by the National Faceless Assessment Center under sections 147 and 148 of the Income Tax Act, 1961, for the assessment years 2016-17, 2018-19, and 2019-20. The petitioners argued that the assessments were arbitrary, illegal, and violated principles of natural justice and constitutional rights. The court's decision was influenced by a previous ruling in W.P.No.25903 of 2022, which addressed similar procedural flaws in the reassessment process under the Finance Act, 2021.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 752782 (HC-TELANGANA)
• Appeal Type: Others
• Pronouncement Date: 20-09-2024
• Assessment Year: misc
• Other Referred Cases: W.P.No.25903 of 2022
• Laws Referred To: Article 226 of the Constitution of India, Income Tax Act, 1961
• Result in Favour of: Revenue
• Court: HIGH COURT
• Department Lawyers: J SUNITHA; B MUKHERJEE
• Assessee Lawyers: THANNERU KUMAR
• Keywords: Faceless assessment; Income tax assessment; Natural Justice; Reassessment Process; Writ of Mandamus
• Section: 147; 148; 144; 148A; 265

Judgement Text

"[ 3411 ] HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) FRIDAY, THE TWENTIETH DAY OF SEPTEMBER TWO THOUSAND AND TWENTY FOUR PRESENT THE HONOURABLE SRI JUSTICE SUJOY PAUL .AND THE HONOURABLE SRI JUSTICE NAMAVARAPU RAJESHWAR RAO rVRlT PETITION NOs: 25378,25379, 25381, 25393, 25413.25417 AND 25428 0F 2024 Between: ANI) 1 li. The Union of lndia, R Department of Revenue, ') 3 ,1 Primary Agriculture Co-Operative Society Limited Chinnakalvala, Rep By lts Secretary VALLAKONDA RAMESH, S/o SADAIAH VALLAKONDA, Occupation Business Aged about 46 years, R/o Chinnakalvala-Vill. SulthanabadMdl Karimnagar Dist 505452,Telangana, lndia. PAN AABAP8659A Assessment Year 201 8- 1 9 ...PETTTTONER(S) The Assistant Commissioner of lncome Tax, Circle 1, Kanmnagar, lncome Tax Office, Aayakar Bhavan, Near Natraj Theatre, Karimnagar Telangana State. The Principal Chief Commissioner of lncome Tax -Telangana and A.P, lT Towers, AC Guards, Masab Tank, Hyderabad 500 028, Telangana. The National Faceless Assessment Center, lncome Tax Department, New Delhi The Central Board of Direct Taxes, Represented by its Chairman Department of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings, New Delhi '1 10 001 epresented by its Secretary to Ministry of Finance, New Delhi the Government ...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 wrrt, order:or direction more particularly one in the nature of Writ of Mandamus declaring the order passed by the lncome Tax WRIT PETITION NO: 25378 OF 2024 authorities (Natronal Faceless E-Assessment centre) completed the assessment UIS 147 r.w.s 144 read with section 1448 of the lncome-tax Act Date of 20-03- 2024, DIN lrBA/AST/s/147t2023-24t1062995578(1)for the Assessment year 2018-19 determining the total income of Rs. 90,30,490/-as arbitrary, illegal, bad in law, without.iurisdiction, void-ab-initio, violative of the principles of natural justice apart from berng violative of Articles 1 , 19(1Xg) and 265 of the Corrstitution of lndia and Sec. 148A of the lncome Tax Act, 1g61, and consequently set aside the same an the interests of justice. Counsel for the Respondent No.1 & 2: M/s. J.SUNITHA, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 25379 OF 2024 Between: PRIMARY AGRICULTURE CO OPERATTVE SOC|ETY GARTKAPADU Rep. By Its Secretary. AKKISETTI RAMAKRTSHNA, S/o VENKATAKRTSHNA 'RAd Occupation. Busrness Aged about 46 years. RiO. Main Road Garikapadu , Kvra Mandal Kharnmam 507165, Telangan-a, lndia. PAN. AABAP9721B Assessm5nt Year.201B-19 ...PETITIONER AND 1 2 The lncome Tax Officer Ward 1, Khammam/ lncome Tax Office. Raieev Gunt Rajiv Chowk, Near Kinnerasani Theatre, Khammam, Telangana Staie. The Principal Ctief Commissioner of lncome Tax-, Telangana and A.p, l.lyderabad, lT Towers, AC Guards, Masab Tank, Hydera-bad -SOO O2S, Telangana. The National Faceless Assessment Center,, Income Tax Department, New Delhi. The central Board of Direct Taxes, Represented by its chairman. Deoartment of Revenue .VlnLstry of Finance. Gov6rnment of rhdia. seireGriat iirirdi;g;, New Delhi -'l 10 001 5. The Union of lndia, Represented_ by its Secretary to the Government, Department of Revenue Ministry of Finlnce, New Dellii _ t tO OOl. - - ' \"-\"' ,..RESPONDENTS J 4 $ .'- -_---- 1_-. Counsel for the Petitioner: SRt THANNERU CHAITANYA KUMAR (') Petitron under Article 226 of the constitution of lndra 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 particularly one in the nature of writ of Mandamus declaring the order passed by the Income Tax Authorities (National Faceless E-Assessment centre) completed the assessment uls 147 r.w.s 144 read with section 1448 of the lncome-tax Act Date of 1 110312024. DIN |rBA/AST tst147 tzoz3-24t1062406482('t)for the Assessment Year 2018-19 determining the total income of Rs. i,35,05,5.19/-as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles of natural justice apart from being violative of Articles 1a, 19(1)(g) and 26b of the constitution of lndia and sec. 14BA of the Income Tax Act, 1961, and consequently set aside the same in th€ interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent No.1 & 2; M/s. B.SAPNA REDDY, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO:25381 OF 2024 Between: ANt) ,I LARGESIZED COOPERATTVE SOC|ETY WyRA, Rep. Bv its Secretarv BOLLAM RAMAKRISHNA, S/o BOLLAM VEERASWAil/I..-occu;;il6\". Business Aggg.+Jt 46 years, R/o- lyq Ar Wyra , eo Wyriwyrirri-uioli, Knammam 5u/165, Ierangana. lndia. pAN- AAAALss,l2F Absesdment year- 2018-19 ...PETITIONER The lncome Tax officer ward 1, Khammam/ lncome Tax office. Raieev Gunt. Rajiv Chowk, Near Kinnerasani Theatre, Khammam, Telangana'Stai;- - - -' The Principa!_ Ciief Commissioner of lncome Tax, Telangana and A,p. Hyderabad, lT Towers, AC Guards, Masab Tank, HyOeriO-aO _ SOO biA, Telangana. The National Faceless Assessment Center,, lncome Tax Department, New Delhi .,2 3 .l The Central Board of Direct Taxes, Represented by its Chairman, Department of Revenue, .M1n1s_try of Finance. Gov6rnment of lhdia Secretariat duid,ngs. New Delhi - 1'10 00'l ...RESPONDENTS Petition under Artrcle 226 of lhe 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 particularly one in the nature of Writ of Mandamus declaring the order passed by the 3rd respondent (National Faceless E-Assessment Centre) completed the assessment UIS 147 read with section 1448 of the lncome-tax Act Date of 2210312024, DIN |TBAiASTlsll4T 12023-2411063202555(1)for the Assessment Year 2018- 19 determining the total income of Rs. 22,98,39,002/-as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles of natural justice apart from being violative of Articles 14, 19(1Xg) and 265 of the Constitution of lndia and Sec 148A of the lncome Tax Act, 1961, and consequently set aside the same in the interests of .justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent No.1 & 2: M/s. B.SAPNA REDDY, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REP. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 25393 OF 2024 Between: 5. The Union of lndia, Represented by its Secretary to the Government, Department of Revenue, Ministry of Finance, New Delhi - 110 001. LARGESIZED COOPERATIVE SOCIETY WYRA, Rep. By tts Secretarv. BOLLAM RAMAKRISHNA, S/o. BOLLAM VEERASWAMI, occupatioi- Pusiness Aged about 46 years, R/O- Wyra At Wyra , Po WyraWyra Mandal, Khammam 507165. Telangana. lndia. PAN- AAAALsSl2F A-ssesdment year- 2016-17 ...PETITIONER The income tax officer, ward 1, Khammam/ lncome Tax Office. Rai eev Grunt. Rajiv Chowk, Near Kinnerasani Theatre, Khammam, Telangana St'aie. -- - \" The Principal CJrref Commissioner of lncome Tax, Telangana and A.p, Hyderabad, lT Towers, AC Guards, l r'lasab Tank, Hyderab\"ad _ SOO O2A, Telangana. AND 1 ) ll. The National Faceless Assessment Center, lncome Tax Department, New Delhi. 4. The Central Board of Drrect Taxes. Represented bv its Chairman. Deoartment of Revenue. Ministry of Finance, Government of lndia, Secretariat Eiuildings, New Delhi - 1 10 001 lj. The Union of lndia, Represented by its Secretary to the Government, Department of Revenue, tvlinistry of Finince, New Del6i - 1j0 001. ...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 particularly one in the nature of Writ of Mandamus or any other appropriate Writ, Order, or Direction, declaring the order passed by the lncome Tax Authorities (National Faceless E-Assessment Centre) completed the assessment U/S j47 read with section 1448 of the lncome-tax Act Date of 24tO3t2OZ4, DIN ITBA/AST/S/'14712023-2411063299670(1)for the Assessment year 2016-12 determining the total income of Rs. 21,79,43,603/-as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio. violative of the principles of natural justice apart from being violative of Articles 1a, 19(1Xg) and 265 of the Constitution of lndia and Sec. 14BA of the lncome Tax Act, 1g6i, and consequenfly set aside the same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHATTANYA KUMAR Counsel for the Respondent No.1 & 2: M/s. B.SAPNA REDDY, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 25413 OF 2024 Between: PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY V V PALEM, Eep By lts Secretary, ITHAGANI THIRUPATHI RAO, S/o. VENKA|AH, Occupation Busrness Aged about 54 years, R/O Eratrve Credit Society V Venkatayapalem. Khammam UrbanKhammam 507318. Telangana, lnijia. PAN AACAPl33BB Assessment Year 2O1B- 19 ...PETITIONER t I 6 ANI) I The lncome tax officer ward 1, Khammam, The lncome tax officer ward 1, Khammam lncome Tax Office, Rajeev Gunt, Rajiv Chowk, Near Kinnerasani Theatre, Khammam, Telangana State. The Principal CJrief Commissioner o{ lncome Tax, Telangana and A. p, Hyderabad, lT Towers, AC Guards. t rlasab Tank, Hyderaiad - 500 O2B, Telangana. 3. The National Faceless Assessment Center, lncome Tax Department, New Delhi 4. The Central Board of Direct Taxes, Represented by its Chairman, Department of Revenue. Ministry of Finance, Government of lhdia, Secretariat duildings, New Delhi - 110 001 5. The Union of lndia, Represented by its Secretary to the Government, Department of Revenue, Ministry of Finance, New Delhi - 110 001. ..,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 particularly one in the nature of Writ of Mandamus, declaring the order passed by the 3rd Respondent (National Faceless E-Assessment Centre) completed the assessment UIS 147 r. w. s 144 read with section 1448 oI the lncome- tax Act Date of 21-02-2024, DIN ITBA/AST/S/14712023-24t106129S168(j) for the Assessment Year 2018-19 determining the total income of Rs. 33,65,98,064/- as arbitrary, illegal, bad in law, without jurisdiction, void- ab- initio, violative of the principles of natural justice apart from being violative of Articles 1a, 1g(1Xg) and 265 of the Constitution of lndia and Sec. 14BA of the lncome Tax Act, .1961, and consequently set aside the same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent No.l & 2: M/s. B.SAPNA REDDY, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA 2 <. I I WFrIT PETITION NO: 25417 OF 2024 AND 1 .lrlTary Agnculture Co-Operative Society Limited, Rep. By lts Secretary, VALLAKONDA RAMESH, S/o SADAIAH VALLAKONDA Occuoatiori- Business Aged about 46 years, R/O- Chinnakalvala-Vill ,sulthana6adMdl Karimnagar Dist 505452,Telangana, lndia. pAN- AABAPB659A Assessment Year- 2019-20 ...PETITIONER The Assistant Commissioner of lncome Tax Circle 1, Karimnagar, lncome Tax Office, Aayakar Bhavan, Near Natraj Theatre, Karimnagar Tel5ngana State. 2 T.ng Principal Ctief Commissioner of lncome Tax, Telangana and A.p, Hyderabad, lT Towers, AC Guards, Masab Tank, Hyder5bad 500 O2g, Telangana. 3. The National Faceless Assessment Center, lncome Tax Department, New Delhi. 4. The Central Board of Direct Taxes, Represented by its Chairman, Department of Revenue. lvlinrstry of Finance. Government of lhdia. secretariat duildings New Delhi - 110 001 5. The Union of lndia, Represented by its Secretary to the Government, Department of Revenue, Ministry of Finbnce, New Del6i - .l 10 001 . ...RESPONDENTS Petition under Article 226 oI 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 particularly one in the nature of Writ of Mandamus declaring the order passed by the lncome Tax authorities (National Faceless E-Assessment centre) completed the assessment UIS 147 r.w.s 144 read with section 1448 of the lncome-tax Act Date of 2010312024, DIN IrBA/AST lsl 1 47 12023-24t 1 062996293 (1 )for the Assessment Year 2019-20 determining the total income of Rs. 1,09,02,235/-as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles of natural justice aiart from being violative of Articles ia, 19(1Xg) and 265 of the Constitution of lndia AND Sec 148A of the lncome Tax Act, 196.1 , and consequently set aside the same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent No.1 & 2: M/s. J.SUNITHA, Jr. SC FOR INCOME TAX >-/-' Between: I Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 25428 OF 2024 Between: AND 1 PRIMARY AGRICULTURE CO OPERATTVE SOCtETYGARTKAPADU. Reo. By its Secretary, AKKISETTI RAMAKRTSHNA, S/o.VENKATAKRISHNA RA6: Occupation. Business Aged about 34 years, R/O. tr/ain Road Garikjpadu ,Wyra Mandal Khammam 507165. Teiangana. lndia. pAN AABApgi2lB Assessment Y ear 2016-17 ...PETITIONER The income tax officer ward 1, Khammam lncome Tax Office. Raieev Gunt. Rajiv Chowk. Near Kinnerasani Theatre, Khammam. Telangana Stale. The Principal Chief Commissioner of lncome Tax. Telanoana and A p Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderab-ad - 500 02g: Telangana. The National Faceless Assessment Center, lncome Tax Department, New Delhi The central Board of Direct Taxes. Represented by its chairman. Deoartment of Revenue, Ministry of Finance, Gov6rnment of thdia, Secretariai tirildi;ga; New Delhi - 110 00i The Union oJ^lndia. Represente-d_ by its Secretary to the Government, Llepa(ment of Revenue Ministry of Finance, New Del6i - 11O 001 ...RESPONDENTS 2 3 .l Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affrdavit filed therewith, the High court may be pleased to issue an appropriate writ, order or direction more particularly one in the nature of writ of [ /andamus declaring the order passed by the lncome Tax Authorities (National Faceless E-Assessment centre) completed the assessment uls 147 read with section 1448 ot the lncome{ax Act Date of 10-03-2024, DlN. ITBAiAST lsl 147 12023-24t 1 062332 a22(1 )for the Assessment y ear 2016-12 determining the total income of Rs. 3,51,94, j13 i as arbitrary, illegal, bad in law, without jurisdiction, vord-ab-initio. violative of the principles of natural justice apart from being violative of Articles 1a, 19(i)(g) and 26s of the constitution of lndia and sec 148A of the lncome Tax Act, 1961, and consequently set aside the same in the interests of justrce. I a'o/ Counsel for the Petitioner: SRI THANNERU CHATTANYA KUMAR Counsel for the Respondent No.1 & 2: M/s. B.SAPNA REDDY, Jr. SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REp. FOR SRI GADI PRAVEEN KUMAR, DEPUTY SOLICITOR GENERIAL OF INDIA The Court made the following: COMMON ORDER THE HONOURABLE SRI JUSTICE SUJOY PAUL AND THE HONOURABLE SRI JUSTICE NAMAVARAPU RAJESHUTAR RAO WRIT PETITION NOS.25378 .25379.25381, 25393. 254L3,254L7 2 Regard being had to the similarity of the question involved, on the joint request of the parties, the matters are ana-logously heard and decided by this common order 3. It is common ground taken by the learned counsel for the petitioner(s) that in furtherance of Finance Act, 2027, re_ assessment process stood modified but the respondents have not taken care of it and therefore notices issued under Section 148 N{p 2542A OF 2024 COMMON ORDER (per Hon'bte Sp,J) Sri Thanneru Chaitanya Kumar, learned counsel appears for the petitioner(s), Ms. J.Sunitha, learned Junior Standing Counsel for Income Tax Department, appears for the respondent(s)-lncome Tax Department in W.P.Nos.25378 and 25417 of 2024, Ms.B.Sapna Reddy, learned Junior Standing Counsel for Income Tax Department, appears for the respondent(s)-lncome Tax Department in W.P.Nos.2S379, 25381, 25393,25413 and 25428 of 2024 and Sri B. Mukherjee, learned counsel representing Sri Gadi Praveen Kumar, learned Deputy Solicitor General of India, appears for the respondent(s)-Central Government in all the writ petitons. I 2 ol the Income Tax Act, 196 1 cannot sustain judicial scrutiny. Since notices are bad in law, the consequential orders are also bad in law. 4 During the course of hearing, learned counsei for the parties agreed that curtains on this issue are finally drawn by this Court in a batch of writ petitions, W.P.No.25903 of 2022 and other connected matters, decided by common order dated 14.O9.2023. The parties agreed that this matter may be disposed of in terms of the Common Order dated 14.09.2023. 5 This Court in the said order dated 74.O9.2023 in W.P.No.259O3 of 2022, held as under: \"35. ln view of the aforesaid discussions, it is by now very clear that the procedure to be followed by the respondent-Department upon treating the notices issued for reassessment being under Section '148A, the subsequent proceedings was mandatorily required to be undertaken under the substituted provisions as laid down under the Finance Act, 2021. ln the absence of which, we are constrained to hold that the procedure adopted by the respondent-Department is in contravention to the statute i.e. the Finance Act, 2021, at the first instance. Secondly, it is also in direct contravention to the directives issued by the Hon'ble Supreme Court in the case of Ashish Agarwal, su pra. 36. Foi all the aforesaid reasons, the 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, the 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 3 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 jurisdiction, 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 Aganval, supra, as a one-time measure exercising the powers under Afticle 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 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. 39. No order as to costs.\" In view of the consensus arrived, the impugned Show 6 Cause notices and consequentia-l orders passed in this batch of ',{,rit petitions are set aside. Liberty is reserved to both the parties to take respective stand and to proceed in accordance with law as per paragraph No.38 of the order dated 14.09.2023 in W.P.No.259O3 of 2022 7 The Writ Petitions are allowed. No costs. Interlocutory applications, if any pending, shall a,lso stand closed. //TRUE COPY' SECTION FICER 1. The Assistant Commissioner of lncome Tax, Circle '1, Karimnagar, lncome Tax Office, Aayakar Bhavan, Near Natra.j Theatre, Karimnagar Telangana State. 2. The lncome Tax Officer Ward-1. Khammam/ lncome Tax Office, Raieev Grunt, Rajiv Chowk, Near Kinnerasani Theatre, Khammam, Telangana Stale. 3. The Principal Chief Commissioner of lncome Tax-, Telangana and AP, Hyderabad, lT Towers. AC Guards, Masab Tank, Hyderabad -500 028, Telangana. ,1. The National Faceless Assessment Center, lncome Tax Department, New To, DM, SD/.MOHD. ISMAIL ASSISTANT REGIS/RAR w r 5. The chairman, central Board of Direct r-axes. Department of Revenue, yinistry of Finance, Governmeni oiinoli, sec,e-t\"rriEriri\"iib.] New Dethi I '1 10 001 6 Jle Secretary to the Government Department of Revenue, Ministry of Finance, New Delhi, Union of lndia. 7 One CC to SRI THANNERU CHAITANYA KUMAR, Advocate [OpUC] B. One CC to M/s J.SUNITHA, Jr SC FOR TNCOME rAX [OPUC] 9. One CC to M/s B.SAPNA REDDY, Jr SC FOR INCOME TAX IOPUC] 'l0.one cc to SRI GAD| PRAVEEN KUMAR, DEpury solrcrroR GENERTAL OF lNDlA, High Court for the State of Telangana at Hyderabad lOpUCi- ' - 'I 1. Two CD Copies BSR BS HIGH COURT DATED: 2010912024 eo({ -t l.,r E s l4 , I i 1s r{orr flt l' D P4rcHEo COMMON ORDER WP.Nos.25378, 25379, 25381, 25393, 25413, 25417 AND 25428 0F 2024 ALLOWING ALL THE WRIT PETITIONS, WITHOUT COSTS U t2 | /'/ eW p "