Zareen Sahar Syed and Mahmood Syed V. Assistant Commissioner of Income Tax, Circle 9(1), Hyderabad and Principal Commissioner of Income Tax, Hyderabad and Additional/Joint/Dy/Asst. Commissioner of Income Tax/Income Tax Officer, National Faceless Assessment Centre, Delhi

WP/20920/2022

AI Insights

The case involves two writ petitions filed by Zareen Sahar Syed and her father, Mahmood Syed, challenging the income tax assessment orders passed against them for the assessment year 2017-2018. The petitioners argued that the assessments were based on a valuation report from the Sub-Registrar, which was not disclosed to them during the issuance of the show cause notices. The respondents, including the Assistant Commissioner of Income Tax and the Principal Commissioner of Income Tax, defended the assessments, asserting that the petitioners had not raised objections at the appropriate time. However, the court found that the non-disclosure of the report constituted a violation of the principles of natural justice, leading to the quashing of the assessment orders.

• Counselvise Citation: [2024] 140 COUNSELVISE.COM (IT) 793887 (HC-TELANGANA)
• Appeal Type: Others
• Pronouncement Date: 11-03-2024
• Assessment Year: misc
• Other Referred Cases: T.Takano vs. Securities and Exchange Board of India and Another, Natwar Singh vs. Director of Enforcement, Dhaleswari Cotton Mills Ltd. v. CIT, Khudiram Das vs. State of W.P., ECIL vs. B. Karunakar
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Others
• Court: HIGH COURT
• Department Lawyers: J V PRASAD
• Assessee Lawyers: VEDULA CHITRALEKHA
• Keywords: Assessment Order; Natural Justice; Sub-registrar; Valuation report; Writ petition
• Section: 143(3); 142(11)

Judgement Text

"[ 337e 1 HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) MONDAY, THE ELEVENTH DAY OF MARCH TWO THOUSAND AND TWENTY FOUR PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE N.TUKARAMJI WRIT PETITION NOs: 21054 and 20920 ot 2022 WRIT PETITION NO: 210s4oF 2022 Assistant commissioner of lncome Tax, Circle 9( 1)'Hyderabad' Principal Commissioner of lncome Tax, Hyderabad-500004. Additional/JoinuDy/ Asst, commissioner of lncome tax/ lncome tax officer ,N;li;;l -F;;.leds Assessment Centre, Delhi ,Govt of lnd!a., MinisJrY of' F,nance, Department of Revenr.rc (CBDT) North Block, New Delhi -1 10001 ..RESPONDENTS Between: Zareen Sahar Syed, D/o. Mahmood Sygd 9ge! 9!9u!14.ye^ats: ,House,wife atoilz Greens'view DR, Algonquin, itlinoisl 60102, USA .Ad-dress.in lndia R6. H.tlo.to-a+stlR, Ftat- ub.ooz, lbrahim Heights, Chanchalguda, Hyderabad, TS -500024 ..PETITIONER AND 1 2 J 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 call for records in respect of the impugned assessment order dt.20- 12-2019 vide ITBA/AST/S/143(3)t2019-2O11022799455(1 passed bv the Assistant commissioner of lncome tax circle 9(1),Hyderabad theist responderlt herein as confirmed by the revision order dL30-3-2o21 vide ITBA/REV/F/REV7l2O2O-2111031957941(i) in revision case No.PClT,Hyderabad-4/revision-264/10000009010712021 passed by the Principal commissioner of lncome tax the 2nd respondent herein and the impugned order dt.31-12-2021 vide ITBA/PNLIF127ON2O21-2211O38298659(1) passed by the ? Additronal/Joint/Dy/ Asst. commissioner of lncome taxl lncome tax officer , National Faceless Assessment centre, Delhi the 3rd respondent herein and issue a writ of Mandamus or any olher writ or order or direction in the nature of Mandamus declaring the said impugned assessment order d1.20-12-201 9 vide ITBA/AST/S/143(3)t2}1g-20t1022799455(1) passed by the 1St respondent as confirmed by the revision order dt.30-3-2021 vide ITBA/REV/FiREV7l2O2O 2111031957g4'.t (',l) passed in revision case No.PClT, Hyderabad-4 /revision-264/ 100000090107t2O21 by the 2nd respondent and the imptigned order dt' 31-12-2021 vide ITBA/PNL/F/270At2021-2211038298659(1) passed by the Additional/JoinvDy/ Asst. commissioner of lncome tax/ lncome tax officer ,National Faceless Assessment Center, Delhi the 3rd respondent as illegal and contrary to law and consequently direct the 1St respondent to pass a fresh assessment order after calling a fresh representation/ the return of income for the assessmenlyear 2017-2018 from the petitioner' lA NO: 1 OF 2022 Petition under Section 151 CPC piaying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to Staytheoperationoftheimpugnedassessmentorderdt.2o-12-2o19vide ITBtuAST/S/14 3(3)t2}1g-20t1022799455(1) passed by the Assistant commissioner of lncome tax circle 9(1), Hyderabad 1st respondent as confirmed by the revision order dt.30-3-2021 vide ITBA/REW/F/REV7l202O- 2111031957g41(1) passed in revision Case No.PClT,Hyderabad-4/revision 264/100000090107t2021 by the Principal commissioner of lncome tax the 2nd respondent and the impugned order dt.31-12-2021 vide ITBA/PNL/F/27ON2021- 22t1038298659(1) passed by the Additional/Joint/Dy/Asst. commissioner of lncome tax/ lncome tax officer , National Faceless Assessment centre, Delhi the 3rd respondent herein pending disposal of the writ petition' Counsel for the Petitaoner: M/s. VEDULA CHITRALEKHA Counsel for the Respondents: SRI J.V.PRASAD, Sr. SC FOR INCOME TAX WRIT PETITION NO:20920 0F 2022 Between: AND 1. 2. 3. vide ITBA/PNL/F/270At2021-2211039541581(1) Additional/JoinVDy/ Asst. commissioner of lncome fiilahmood Sved. s/o. Late Syed Ruhullah aged about 69 years Occ. ' ausiness, R/o. 512 Greens view Di' lllinois, 60102,. USA . AddreSS ln lnola Hb.\"' H.tlt;. - ro-e--aE,e,rrai- t'to.ooz, lbiahim Heishts chanchalguda' Hyderabad. ...PETITIONER lncome Tax Officer, Ward 9(1),Hyderabad' Principal Commissioner of lncome Tax, Hyderabad - 500004 Additional/JoinUDy/Asst.commissioneroflncometax/,lncome.taxofficer ,N;ii;;;l F;;\"leds nssessmeni Gnt,\", Delhi-.Govt of lndia' Minis-try of F#;;; o\"pr-iru\"i oinevin,re (CBDT) North Block, New Delhi -110001 ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybe pleased to call for records in respect of the impugned assessment order dt.26t'l2t2o1g vide ITBA/ASTt$t143(3)12019- 20t1023162671 passed by lncome Tax officer Ward 9(1),Hyderabad the ,1st respondent herein as confirmed by the revisionorderdt.3ot3l2o2lvideITBA/REvtFtREv7l2o20-21/1031958418(1)in PCIT Hyd-4/Revision-264/100000 OgO11Ot2O21 passed by the Principal Commissioneroflncometax,Hyderabadthe2ndrespondenthereinandthe impugned order dt.9-2-2022 vide |TBNPNLIFl2TOAt2O2l-2211039541581(1) passed by the Additional/Joint/Dy/ Asst. commissioner of lncome tax/ lncome tax officer ,National Faceless Assessment centre, Delhi the 3rd respondent herein and issue a writ of Mandamus or any other writ or order or direction in the nature of Mandamus declaring the said impugned assessment order d1.26-12-2019 vide ITBA/AST/S/143(3)/2019-20110231626TlpassedbylncorneTaxofficerWard 9(1),Hyderabad the'tst respondent as confirmed by the revision order dt.30-3- 2021 vide ITBA/REV/F/REV7l2O2O 21t1031g57g58418(1) in PCIT Hyd- 4/Revision - 26411OOOOOOgO11Ol2O21 passed by Principal commissioner of lncometax,Hyderabadthe2ndrespondentandtheimpugnedorderdt.9-2-2022 passed bY the tax/ lncome tax officer ,National Faceless Assessment centre, Delhi the 3rd respondent herein as illegalandcontrarytolawandConsequentlydirectthe'lStrespondenttopassa fresh assessment order after calling a fresh representation / the return of income for Assessmen I year 2O17 - 20 18 from the petitioner' IA NO:1OF 2022 PetitionunderSectionl5lCPCprayingthatinthecircumstancesstated in the affidavit filed in support of the petition, the High Court may be pleased to stay the operation of the impugned assessment order dt 26-12-2019 vide ITBtuAST/S/143(3)t2}1g-20t1023162671 passed by the lncome Tax Officer Ward 9(1),Hyderabad the 1st respondent herein as confirmed by revision order dt.30-3-2021videITBA/REvtFlREvTl2o2o-21t1031957958418(1)inPClTHyd- 4/Revision-264/l0o000og0llol2o2lpassedbythePrincipalCommissionerof lncome tax, Hyderabad the 2nd respondent herein and the impugned order dt 9- 2-2022 vide ITBA/PNL/F/270At2O21-2211039541581(1) AdditionaliJoint/Dy/ Asst. commissioner of lncome tax/ passed bY the lncome tax officer ,NationalFacelessAssessmentCentre,Delhithe3rdrespondenthereinpending disposal of the writ Petition Counsel for the Petitioner: M/s. VEDULA CHITRALEKHA Counsel for the Respondents: SRI J'V'PRASAD' SC FOR INCOME TAX The Court made the following: COMMON ORDER THE HON'BLE SRI JUSTICI P.SAM KOSI{Y AND THE HON'BLE SRI JUSTICE N.TUI(ARAMJI WRIT PETITION Nos.2lO54 and 2O92O of 2O22 COMMON ORDER: (per Hoft'ble Si Justice P.SA.a KosEy) These are two writ petitions where the petitioners/assessees are daughter and father respectively challenging the assessment orders dated 20.12.2019 and 26.12.2019 passed by respondent No. 1 under Section 143 (3) of the Income Tax Act, 1961 (briefly referred to hereinafter as the Act') for the assessment year 2Ol7- 20t8. 2. Heard Ms. Vedula Chitralekha, learned counsel for the petitioner and Mr. J.V.Prasad, learned Senior Standing Counsel for Income Tax.appearing for the respondents. 3. The petitioners herein initially filed their income tax return vide e-filing on 19. 11.2077 and 31.10.2017 respectively. However, due to oversight, there was arl error reflected under the long term capital gains. The petitioners therein filed a revised return on 06.12.2017 and these revised returns were processed and accepted by the respondent authorities. Subsequently, the revised returns submitted by ttre petitioners were subjected to scrutiny and a notice under Section I42 (ll of the Act was issued to which the 2 petitioners immediately responded. Without considering the submissions which the petitioners have raised, respondent No. I has passed the impugned assessment orders d,ated. 20.12.2019 and 26.12.2019 respectively, both of which are under chailenge in the two instant writ petitions. 4. Though the learned counsel for tlle petitioner had raised various other grounds assailing the impugned orders, however, at the first instance she contended that the impugned orders are bad for the simple reason that they are passed relying upon the valuation report submitted by the Sub-Registrar. It is the contention of the learned counser for the petitioner that the valuation report and its details were not made available to ttre petitioners while issuing show cause notice and therefore there was clear violation of.the principles of natural justice. 5. It was also the contention of the learned co,nser for the petitioner that from plain reading of the contents of the impugned orders i.e. the two assessment orders, it would crearry reflect that the show cause notice in both the cases were issued prior to obtaining the Sub-Registrar,s valuation report. Therefore the petitioners were not in a position to give an effective reply to the show cause notices. It was further contended t.Ilat apart from trre fact that it has been obtained subsequent to the show cause J 7 notices, these valuation reports were not made available to the petitioners to peruse nor were they permitted or given an opportunity to frle their objections if any. 6. The whole contention of the learned counsel for the petitioner was that once when the respondent aut-horities in the course of passing of an order relies upon certain documents which in the instant cases were the Sub-Registrar's valuation report, it was incumbent upon the Assessing Offrcer to have made available the Sub-Registrar's report to the petitioners enabling them to file their response to ttre said reports. In the absence of which the assessment. order remains to be an assessment order which has been passed taking into consideration certain extraneous documents and the contents of which were either not made available to the petitioners nor was it formed part of the show cause notices itself. Thus, the entire action stands vitiated on this ground alone. 7 . l.earned counsel for t]re petitioner heavily relied upon the decision of ttre Honble Supreme Court in the case of T.Takaao vs. Securities and Exchange Board of India aad Anotherr wherein the Honble Supreme Court had ordered for quashment of al order which was passed relyrng upon certain documents which were t (2024 a Supreme Court Cases 162 4 either not formed part of the show cause notice nor was the same made available to the petitioners. 8. On tJle previous date of hearing, we had requested the learned Senior Standing Counsel for Income Tax Department to seek instructions particurarry on the aspect whether the report of the Sub-Registrar was made available to the petitioners arong with the show cause notices or the contents of Sub_Registrar,s report being reflected in the show cause notice itself. 9. Today when the matter is taken up for hearing, the learned Senior Standing CounseI for lncome Tax Department upon instructions submits that from the materials made available to him by the Department, it is not reflected that the Sub-Registrar,s report was made part of the show cause notice or the contents of which were reflected in the show cause notice. 10. It was contended by ttre learned Senior Standing counsel for Income Tax Department that the petitioners in fact had not raised this ground all along and therefore they are estoppeled from raising this ground at this belated stage. It was further contended that upon plain reading of the two show cause notices by itself would reveal that the basis for issuance of the said impugned orders was the Sub-Registrar,s report; however, the petitioners did not seek for 5 the said report or its contents. Nor did they raise their objections on the sami at any point of time. 11. Thus from the admitted factual matrix, it stands established that the Sub-Registrar's report was not attached to the show cause notices nor was the contents of the same made available to the petitioners. Another striking feature which is reflected is the fact that the impugned orders have been passed strictly based upon valuation report submitted by the Sub-Registrar. 12. Under the given factual matrix of the case, if we now look into the contents of the judgment of the Hon'ble Supreme Court in the case of T.Takaao (supra), the Hon'ble Supreme Court has dealt with that issue elaborately where referring to past precedents in paragraph No.37 has held as under: \"37 . During the course of the adjudication, the fundamental principle is that material which is used against a person must be brought to notice. As this Court observed: (Natwar Singh casez, SCC p. 269, paras 3O-31) '3O. The right to fair hearing is a guaranteed right. Every person before an authority exercising the adjudicatory powers has a right to know tJ.e evidence to be used against him. This principle is frrmly established and recognised by this Court in Dhaleswari Cotton Mills Ltd. v. CIT [AIR 1955 SC 65 : (1955) 1 SCR 9411 However, disclosure not necessarily involves supply of the material. A person may be allowed to insPect the hle and take notes. Whatever mode is used, the fundamental principle remains that nothing should be used against the person which has not been brought to his notice. If _t 2 Natwar Singh v. Director of Entorcement, (2OlO) l3 SCC 255 6 relevant materia.l is not disclosed to a party, there is prima facie unfairness irrespective of whether the material in question arose before, during or aJter the hearing. The law is fairly well settled if prejudicial aJlegations are to be made against a person, he must be given particulars of that before hearing so that he can prepare his defence. However, there are variou s exceptions to this general rule where disclosure of evidential material might inflict serious harm on the person directly concerned or other persons or where disclosure would be breach of confidence or might be injurious to the public interest because it would involve the revelation of ofhcial secrets, inhibit frankness of comment and the detection of crime, might make it impossible to obtain certain clauses of essential information at a-l I in the future (see R. v. Secy. of State for Home Deptt., ex p H [1995 QB 43 : (19941 3 wLR 11 l0 : (1e95) I All ER 479 (CA)I l. 31 . The concept of faimess may require the adjudicating authority to furnish copies of those documents upon which reliance has been placed by him to issue show-cause nolice requiring the noticee to explain as to why al inquiry under Section 16 of the Act should not be initiated. To this extent, the principles of natural justice and concept of fairness are required to be read into Rule 4( 1) of the Rules. Fair procedure and the principles of natural justice are in-built into the Rules. A noticee is always entitled to satisfy the adjudicating authority that those very documents upon which relialce has been placed do not make out even a prima facie case requiring any further inquiry. In such view of tJle matter, we hold that all such doiuments relied on by the authority are required to be furnished to the noticee enabling him to show a proper cause as to why an inquiry should not be held against him though the Rules do not provide for the same. Such a fair reading of the provision would not amount to supplanting the procedure laid down and would in no manner fnrstrate the apparent purpose of the statute.' (emphasis supplied) 13. Further, in paragraph Nos.50, 51, 53 and 54 of the above judgment, the Hon'ble Supreme Court has laid down the following principles which for ready reference are reproduced herein under: 7 \"5O. The following principles emerge from the above discussion: 50.1. A quasi-judicial authority has a duty to disclose the material that has been relied upon at the stage of adjudication. 5O.2. An ipse dixit of the authority that it has not relied on certain material would not exempt it of its liability to disclose such material if it is releuanf to and has a nerus to the action that is taken by the authority. In all reasonable probability, such material would have influenced the decision reached by ttre authority. 5O.3. Thus, the actual test is whether the material that is required to be disclosed is relevant for purpose of adjudication. If it is, then the principles of natura.l justice require its due disclosure. 51. The investigation report forms the material considering which, the Board arrives at a satisfaction regarding whetleer there has been a violation of the regulations. If it is satisfred that there has been a violation of the regulations, after giving a reasonable opportunity to be heard, the Board is empowered to take action according to Regulations 11 and 12. It would not suffice for the frrst respondent to claim as it did before the High Court that it did not rely on the investigation report. The ipse dixit of the authority that it was not influenced by certain material would not suIlice. If the material is relevant to and has a nexu s to PART C the stage at which satisfaction is reached by an auttrority, such material would be deemed to be important for the purpose of adjudication. The written submissions of the Board clearly state that the frndings of the investigation report are important for the authority to decide whether there are any prima facie grounds to initiate enforcement proceedings under Regulation 1O. The relevant extract of the submissions is reproduced below: \"It is submitted that Regulation 9 of PFUTP Regulations require the Investigating Authority to submit the report after completion of the investigation to the appointing authority. However, the provision does not require furnishing of the report to the Noticee. Further, the investigation report is merely a culmination of documents which tlle 'lnvestigating authority relies on/come across while conducting the investigation and is not a piece of evidence in itself. It is a report which is necessary for an authority, who orders an investigation, to decide as to whether there 8 ( are prima-facie grounds to initiate enforcement proceedings or not. Therefore, before the authority makes up his mind, he will either himself investigate or direct his subordinates to investigate in the -^it\".. It is only after the authority receivei the report of the investigation that he can decide as to whetlier action is called for or not. Therefore, the investigation report is in the nature of i\"t.._a\"epart-.i,rt\"f communications between olficers investigating the matter and authorit5r who can de-cide \" arry enforcement action against the entity. The findings recorded in the investigation report against the Noticee are brought out in the SCN ana t}le copies of all the documents that are relied upon by SEBI, while issuing the SCN are always shared with tire concernea. The present case is no exception.\" (emphasis \"rfpn.ay 53. In Khudiram Das3, a four_Judge Bench of this Court lai{.aow-n a two-prong test for the standard of ,..i.r,rrr.y,; firstly, the material must have nexus with the order and secondly, the material might have influenced the decision o{ the authority. A Constitution Bench of this Court in Karunakar+ held that the non-disclosure of the relevant information is not in itself sullicient to warrant the setting aside of the order of punishment. It was held ttrat in order to set aside the order of punishment, tfre aggrieved person must be able prove tJ.at prejudice has been caused to him due to non-disclosure. To prove prejudice, he must prove that had the material been disclosed to him the outcome or the punishment would have been different. The test for tlle &tent of di\"\"to\"r.. 1rd B\" corresponding remedy for non-discio\"r.\" i\" dependent, on the objective thai the disclosure slets to ac_hi9ve. Therefore, tJ.e impact of non_disclosure on the reliability of the verdict must also be determinea vis_a_ vis, the overa_ll fairness of the proceeding-.- While determining the reliability of the verdici ana pun'isfrment, the court must also look into the possible'uses of the undisclosed information for purposes anciltary to ttre outcome, but that which might have impacted the ve!diq! I Khudiram Das v. State of W.p., (197S) 2 SCC 8t : 1975 SCC (CnJ 43S a ECIL v. B. Karunakar, (1993) 4SCC 227 : tgg3 SCC (L&S) I t8; 9 / 54. In Natwar Singhs, it was held that materia-l which is relevant to the subject-matter of the proceedings must be disclosed, unless the scheme of the statute indicates to the contrar5z. The non-disclosure of such material is prima facie arbitrary. A deviation from this general rule was made based on tle stage of the proceedings' It was held that it is sufficient to disclose the materials relied on if it is for the purpose of issuing a show cause notice for initiating inquiry. However, in the present case, since the report of the investigating authority under PART C Regulation 9 enters into the calculus of circumstances borne in mind by the Board in arriving at its satisfaction under Regulation 10 for taking actions as specified in Regulations 11 and 12, it would be contrary to the Regutations to assert that the investigation report is meiely an internal document of which a disclosure is not warranted. In arty event, the language of Regulation 10 makes it clear that the Board forms an opinion regarding the violation of Regulations after considering the investigation report prepared under Regulation 9' Thus, the investigation report has to be duly disclosed to the noticee. However, the right to disclosure is not absolute' It needs to be determined if tl:e non-disclosure of the investigative report is protected by any of the exceptions to the rule.\" 14. From the aforesaid facts and circumstances, admittedly the Sub-Registrar's report was not made available to the petitioners along with the show cause notices or at a subsequent stage at all' If we look into the principles laid down in tJle aforesaid judgment by the Hon'ble Supreme Court and the facts of the instant writ petitions, admittedly two show cause notices were issued to the petitioners but in either of the two, a copy of the Sub-Registrar's report was not enclosed. In Writ Petition No.2O920 of 2022 whete the assessee is the father, neither was the report of the Sub- Registrar made available nor was the contents of which reflected in s Natwar Singh v. prrectir of Enforcement, (2010) 13 SCE 255 I I 10 the show cause notice and to make things bad when the impugned assessment order had been passed, heavy reliance has been placed upon the Sub-Registrar's report. Thus, from the ratio laid down by the Hon'ble Supreme Court in the case of T.Takano (supra), we do not. have any hesitation in reaching to the conclusion that the impugned orders smacks arbitrariness on the part of the respondent authorities in passing the same. 15. Another striking feature what is reflected from the proceedings is the fact that the show cause notices issued and the final assessment orders passed at a very short period of time gap. This also compels this Bench to draw an interference against the respondent authorities in showing undue haste in passing of the assessment orders. In Writ Petition No.21054 of 2022, the show cause notice was issued on 14.12.2019 and the assessment order was passed on 20.12.2019 i.e. in less than a period of six (06) days. Likewise, in Writ Petition No.20920 of 2022, the show cause notice was issued on 2I.12.2019, the date of appearance for personal hearing was given on 23.12.2019 and the final assessment order has been passed on 26.12.2O19 which itself establishes that in less than around frve (05) days, the entire proceedings had been initiated and concluded which therefore vitiates the whole order. ( ry / 11 16. In the given factual matrix, the impugTled orders to the aforesaid extent of having passed without providing a coPy on the basis of which the proceedings were initiated, deserves to be and are accordingly set aside/quashed. Since we a-re interdicting the impugned orders only on the ground of the same being violative of the principles of natural justice, it would be left open for the respondent authorities to take appropriate decision in accordance with the law. 17. With the above observations, the two writ petitions are allowed. There shall be no order as to costs. Consequently, miscellaneous petitions pending if any, shall stand closed. To, 1. 2. 3. 4. 5. 6. 7. BSR SD/-N. SRIHARI ASSISTANT REGISTRAR //TRUE COPYII {r\" SECTION OFFICER The Assistant commissioner of lncome tax, Circle 9(1), Hyderabad' The Principal Commissioner of lncome Tax' Hyderabad-500004' TheAdditional/JoinUDy/Asst,commissioneroflncometax/lncometax-officer, N;t#;i F;;6ss Ass'essmehi centre, Qelhi ,Gqv.t of lndia' Ivlinistry.of ^. F';;;A'D.-p;;eni ot nerenue paol North Block, New Delhi -1 10001 The lncome Tax Officer, Ward 9(1 ),Hyderabad. One CC to M/s. VEDULA CHITRALEKHA, Advocate TOPUCI one cc to sitlJ.V.PRASAD, SC FOR INCOME TAX [OPUC] Two CD Copies LS b / HIGH COURT DATED: 1110312024 os 1CE STa fc 2 B rlAR 2024 D6,SPATCh'gO € J o ( i; L) t COMMON ORDER WP.Nos.21054 and 20920 of 2022 ALLOWING BOTH THE WRIT PETITION, WITHOUT COSTS trt cp(' @ .x "