Counsel Forthe Respondent Nos. 1 & 2: Ms. B. Sapna Reddy,Representing Sri J v. Prasad, S.c. For Income Tax

HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD(Special Original Jurisdiction)TUESDAY, THE THIRTIETH DAY OF APRILTWO THOUSAND AND TWENTYFOUR - PRESENT -THE HONOURABLE SRI JUSTICE SUJOY PAUL ANDTHE HONOURABLE SRI JUSTICE N.TUKARAMJI - WRIT PETITION Nos.1 1830 11835 11846 11847 11855 1187111890 11913 11915 11927 AND 11939 0F 2024 WRIT PETITION No.1183O OF 2024 Between: Rashmi Gandam, W/o G. Ravi, aged about 39 years, Occupation Business, Rl/o H.No. 4-12-2411 Plot No 35, Hayaynagar, Arunodayanagar, Vanastalipuram,Rangareddy 500070, Telangana, lndia PAN: Assessment Year.2016-17 ...PETITIONER AND '1. Office of The lncome Tax Officer Ward 9(1), Hyderabad, Telangana State. 2. The Principal Chief Commissioner of lncome Tax Telangana and A.P,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad 500 028,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad 500 028,Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001 .of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001 . 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represented by its Secretary to the Govemment,Department of Revenue, tVlinistry of Finance, New Delhi - 110 001 [.]Department of Revenue, tVlinistry of Finance, New Delhi - 110 001 [.] ...RESPONDENTS Petition under Article 226 of the Constitution of lndia [praying ]that in thecircumstances 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, orDirection, declaring the order passed by the lncome Tax Authorities (NationalFaceless E-Assessment centre completed the assessment u/s 147 rlw Section144-9 of the lncome Tax Act, ['1961 ]vide DIN and Notice No. dated 2910212024,ITBA/AST/S/14712023-2411061740260(1) for the assessment year 2O16-l Tdetermining the total income of Rs. 62,08,433/- as arbitrary, illegal, bad in law,without [jurisdiction, ]void-ab-initio, violative of the principles of natural justiceapart from being violative of Articles 14, 19(1)(9) and 265 of the constitution oflndia AND Sec. 14BA of the lncome Tax Act, 1961, end consequently set asidethe same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel forthe Respondent Nos. 1 & 2: Ms. B. SAPNA REDDY,REPRESENTING SRI J. V. PRASAD, S.C. FOR INCOME TAX Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERAL OF TNDIA WRIT PETITION NO: 11835 0F 2024." Between: Panta Reddy Mary Vindhya Rani, S/o. [panta ]Reddy Joseph Reddy, Aoed about 56years,. Occupation: Business, Ryo. '12-5-84185 A Vij-ayapuii Colony, Soith LalaqudaTamaka Tamaka, Secunderabad 500017, felang-ana, lndia pAirl: BWVPRTd4OCAssessment Year: 201 5-1 6 ---...PETITIONER AND 1. Office of The lncome Tax Officer, Ward-15(1), Hyderabad, Telangana State. 2. The Principal Cfrief Commissioner of lncome Tax -Telangana and A.p,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 O2g,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 O2g,Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Rerrenue, _Minis^try of Finance, Government ot lhOia, Secretariat Eiuildings,New Delhi - 1'10 001 .of Rerrenue, _Minis^try of Finance, Government ot lhOia, Secretariat Eiuildings,New Delhi - 1'10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. ---...PETITIONER AND 1. Office of The lncome Tax Officer, Ward-15(1), Hyderabad, Telangana State. 2. The Principal Cfrief Commissioner of lncome Tax -Telangana and A.p,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 O2g,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 O2g,Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Rerrenue, _Minis^try of Finance, Government ot lhOia, Secretariat Eiuildings,New Delhi - 1'10 001 .of Rerrenue, _Minis^try of Finance, Government ot lhOia, Secretariat Eiuildings,New Delhi - 1'10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5. The Union of India, Represented by its Secretary to the Government,Department of Revenue, Ministry of Finbnce, New Delhi - 110 OOi.Department of Revenue, Ministry of Finbnce, New Delhi - 110 OOi. ...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 thenature of Writ of Mandamus, declaring the order [passed ]by the [lncome ][Tax]Authorities (National Faceless E-Assessrnent [Centre completed ][the ][assessment]UtS '147 r/w Section 144-8 of the lncome [Tax ][Act, ][1961 ][vide ] [and ][Notice ][No.]dated 13-03-2024 ITBAiAST lst147t2o23-2411062b19743(1) [for the ][assessment]year 2O15-16 determining the total income of Rs. 88,06,350/- 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 theConstitution 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 Counsel for the Respondent Nos. [1 ][& ][2: ][Ms. ][B. ] [REDDY'-]REPRESENTING SRI J. V. PRASAD, S.C. [TAX,-] Counsel for the Respondent Nos.3 DEPUTY SOLICITOR GENERAL OF to [5: ] [KUMAR' ] - WRIT PETITION NO: 11846 OF [2024] Between: MOHAMMED AKRAM, S/o SHAIK [HUSSAIN, ][Aged about ][50 ][years,]Occuoation Business, Rl/o [H.No.'l ][-8- ][11511117 ][Kareem Compound, ] [Road]Ramdopalpet, Hyderabad 5OO0O3, [Telangana, ][lndia ][PAN: ][ ]Assessment Year: [201 5-1 ][6] ...PETITIONER(S) AND 1. Office of The lncome [Tax Officer Ward 4(1), Hyderabad/, Telangana ][State.] 2. The Principal Chief Commissioner [of ][lncome ][Tax ][Telangane ]9!q l:i'Hyderabad, tT Towers, AC Guards, [Masab ][Tank, ][Hyderabad ][5O0 028']Telangana.Hyderabad, tT Towers, AC Guards, [Masab ][Tank, ][Hyderabad ][5O0 028']Telangana. 3. The Central Board [of Direct Taxes, Represented by its Chairman, Department]of Revenue Ministry of [Finance, Govemment ][of ][lndia, Secretariat BuiHings']New Delhi - 110 [001 ][.]of Revenue Ministry of [Finance, Govemment ][of ][lndia, Secretariat BuiHings']New Delhi - 110 [001 ][.] 4The National [Faceless Assessment ][Center' lncome ][Tax ][Department' ][New]DelhiDelhi 5. TheUnion of lndia, [Represented ][by its ][Secretary ][to ][the ][Government']Dep,;;;;i oin"uenr., [t',tinistry ][of Finbnce, New Delhi ][- ][110 ][001]Dep,;;;;i oin"uenr., [t',tinistry ][of Finbnce, New Delhi ][- ][110 ][001] ...RESPONDENTS 3. The Central Board [of Direct Taxes, Represented by its Chairman, Department]of Revenue Ministry of [Finance, Govemment ][of ][lndia, Secretariat BuiHings']New Delhi - 110 [001 ][.]of Revenue Ministry of [Finance, Govemment ][of ][lndia, Secretariat BuiHings']New Delhi - 110 [001 ][.] 4The National [Faceless Assessment ][Center' lncome ][Tax ][Department' ][New]DelhiDelhi 5. TheUnion of lndia, [Represented ][by its ][Secretary ][to ][the ][Government']Dep,;;;;i oin"uenr., [t',tinistry ][of Finbnce, New Delhi ][- ][110 ][001]Dep,;;;;i oin"uenr., [t',tinistry ][of Finbnce, New Delhi ][- ][110 ][001] ...RESPONDENTS Petition under [Article ][226 ][of ][the ][constltution ][of ][lndia ][praying ][that in ][the]circumstances [stated ][in ][the ][affidavit ][filed ][therewith' ][the ][High Court may ][be]pleasedtoissueanappropriatewrit'orderordirectionmoreparticularlyoneinthenatureofWritofMandamusoranyotherappropriateWrit,order,orDirection,the [order passed by ][the ][lncome ][Tax ][Authorities ][(National Faceless ] declaring Assessment [Centre completed ][the ][assessment ] [,147 ][rlw Section ][144-B ][of ][the]lncome Tax [Act, ]['1961 ][vide ] [and ][Notice ][No ][dated ][17 ][-03-2024]ITBA/AST/S/147t2o23.24t1062795294(1)fortheassessmentyear20l5-16the [total ][income ][of ][Rs. ][73,47,650/-as ][arbitrary, illegal, ][bad ][in ][law']determining without [jurisdiction, void-ab-initio, violative ][of the ][principles ][of ][natural justice apart]from being violative [of ][Articles ][1 ][a, ][19(1 ])(g) [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: ] [^] Counsel forthe [Respondent ][Nos. ][1 ][& ][2: ][Ms' B' ] [REDDY']REPRESENTING [J. V. ][PRASAD, ][S'C. ] Counsel for the [Respondent ][Nos.3 ][to ][5: ] [KUMAR']DEPUTY SOLICITOR WRIT PETI [NO: ][11][ 847 ][0F ][2024 ][.--'] Between: GORTGE SRISAILAM, [S/o. GORIGE SATHAIAH, aged ][about 53years,-occupation.]d,i.i"".",-ny..-Ju.Jir"tf"VlfftUeacnat [Road, ][Mdl 6utubullapur^R. ][R. ][Dist-5o0055']i;ilg;;;, lnaia [pRN' ] [Assessment ][Year ][2018-19] ...PETITIONER AND 1. Office of The lncome Tax Officer Wald 2 (1), Hyderabad, Telangana State. 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.PHyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028,Telangana. 3- The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - ['1 ]10 001 .of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - ['1 ]10 001 . 4. The National Faceless Assessment Center' lncome Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represeflted by its Secretary to the Govemment,Department of Revenue, Minislry of Finance, New Delhi - 110 001 .Department of Revenue, Minislry of Finance, New Delhi - 110 001 . ...RESPONDENTS 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.PHyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028,Telangana. 3- The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - ['1 ]10 001 .of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - ['1 ]10 001 . 4. The National Faceless Assessment Center' lncome Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represeflted by its Secretary to the Govemment,Department of Revenue, Minislry of Finance, New Delhi - 110 001 .Department of Revenue, Minislry of Finance, New Delhi - 110 001 . ...RESPONDENTS Petition under Article 226 of lhe Constitution of lndia praying that in thecircumstances stated in the affidavit filed therewith, the High Court may bepleased to issue an appropriate writ, order or direction more particularly one in thenature 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 147 dw Section 144-B of thelncome Tax Act, 1961 vide DIN and Notice No. dated 07 -03-2024ITBA/AST/S/14712023-2411062186256(1) for the assessment yea( 2O18-l9determining the total income of Rs. 63,26,6221-as atbi|:rary, illegal, bad in law,without [jurisdiction, ]void-ab-initio, violative of the principles of natural [justice ]apartfrom being violative of Articles 14, 19(1)(g) and 265 of the Constitution of lndia andSec. 148A of the lncome Tax Act, 1961, and consequently set aside the same inthe interests of [justice.] Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent Nos. 1 & 2: Ms. B. SAPNA REDDY, [--']REPRESENTING SRI J. V. PRASAD, S.C. FOR INCOME TAX Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR, .- DEPUTY SOLICITOR GENERAL OF INDIA WRIT PETITION NO: 11 85s OF 2024 Between: RAMA DEVI MEDAGAM, S/o.Vittat ReQdy Shepaily, aged about 51 years,Occupation: Business Rl/o 6-14-128, Nambeviayadal Nizamabad SO'SOOZ,-H No. Telangana, lndia. PAN: Assessment year: 2016-11 ...PETITIONER AND 1. Office of The lncome Tax Officer Ward 1, Nizambad, Telangana State. 2. The Principal Clrief Commissioner of lncome Tax, Telangana and A.p,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderab"ad - SOO Oig,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderab"ad - SOO Oig,Telangana. 3. The central Board of Direct raxes, Represented by its chairman, Deoartmentof Revenue, Minisrry of Finance, Gov6rnment or rhoia. secreGriai Eiuidi;s",New Delhi - ['1 ]10 001.of Revenue, Minisrry of Finance, Gov6rnment or rhoia. secreGriai Eiuidi;s",New Delhi - ['1 ]10 001. 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represented_ by its Secretary to the Govemment,Department of Revenue, Ministry of Finince, New Delhi _ j 1O 00i.Department of Revenue, Ministry of Finince, New Delhi _ j 1O 00i. ,..RESPONDENTS -./ 3. The central Board of Direct raxes, Represented by its chairman, Deoartmentof Revenue, Minisrry of Finance, Gov6rnment or rhoia. secreGriai Eiuidi;s",New Delhi - ['1 ]10 001.of Revenue, Minisrry of Finance, Gov6rnment or rhoia. secreGriai Eiuidi;s",New Delhi - ['1 ]10 001. 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represented_ by its Secretary to the Govemment,Department of Revenue, Ministry of Finince, New Delhi _ j 1O 00i.Department of Revenue, Ministry of Finince, New Delhi _ j 1O 00i. ,..RESPONDENTS -./ Petition under Article 226 of the constitution of lndia praying that in thecircumstances stated in the affidavit filed therewith, the High court may bepleased to issue an appropriate writ, order or direction more particularly one in theappropriate writ, order or direction more particularly one in thenature of writ of Mandamus declaring the order passed by the lncome TaxAuthorities (National Faceless E-Assessment centre) completed the assessmentuls 147 read with section 144B of the lncome-tax Act Date of order o1lo2l2o24,DIN lrBA/AST/sl 1 47 12023-2411 060366930(1 ) for the Assessment y ear 2o1 6-1 luls 147 read with section 144B of the lncome-tax Act Date of order o1lo2l2o24,DIN lrBA/AST/sl 1 47 12023-2411 060366930(1 ) for the Assessment y ear 2o1 6-1 ldetermining the total income of Rs. 21,00,000/- as arbitrary, illegal, bad in law,without jurisdiction, void-ab-initio, violative of the principles of natural justice apartfrom being violative of Articles 1a, $()(g) and 265 of the constitution of lndia andSec. 148A of the lncome Tax Act, 'r96'r, and consequently set aside the same inthe interests of justice.without jurisdiction, void-ab-initio, violative of the principles of natural justice apartfrom being violative of Articles 1a, $()(g) and 265 of the constitution of lndia andSec. 148A of the lncome Tax Act, 'r96'r, and consequently set aside the same inthe interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR _/ Counsel for the Respondent Nos. 1 & 2: Ms. J. SUNITHA,JUNIOR STANDING COUNSEL REPRESENTINGMs. SUNDART R [ptSUpATt, ]SENTOR S.C. FOR TNCOME TAX Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERAL OF INDIA WRIT PETITION NO: 11871 oF 2024 Between: Primary Aglculture Co-Operative Society Limited, Rep. by its Secretary, GaddiThirupathi, S/o.Gaddi Mallaiah, Aged about 32 years, Ryo. H.No.1- 42 AppinnapetaVill, Peddapally Mdl Karimnagar 505174, Telangana, lndia PAN: AABAPB1OBCAssessment Year: 2O19-2OVill, Peddapally Mdl Karimnagar 505174, Telangana, lndia PAN: AABAPB1OBCAssessment Year: 2O19-2O ...PETITIONER -- AND 1 . Office of the lncome tax officer ward 2, Karimnagar, Telangana State. 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.P,Hyderabad, lT Towers, AC Guards, IVlasab Tank, Hyderabad- 500 028,Telangana.Hyderabad, lT Towers, AC Guards, IVlasab Tank, Hyderabad- 500 028,Telangana. 3. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 4. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001.of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001. 5. The Union of lndia, Represented by its Secretary to the Govemment,Department of Revenue, Ministry of Finance, New Delhi - ['l ]10 001 .Department of Revenue, Ministry of Finance, New Delhi - ['l ]10 001 . ...RESPONDENTS 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.P,Hyderabad, lT Towers, AC Guards, IVlasab Tank, Hyderabad- 500 028,Telangana.Hyderabad, lT Towers, AC Guards, IVlasab Tank, Hyderabad- 500 028,Telangana. 3. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 4. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001.of Revenue, Ministry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 110 001. 5. The Union of lndia, Represented by its Secretary to the Govemment,Department of Revenue, Ministry of Finance, New Delhi - ['l ]10 001 .Department of Revenue, Ministry of Finance, New Delhi - ['l ]10 001 . ...RESPONDENTS Petition under Article 226 ol the Constitution of lndia praying that in thecircumstances stated in the affidavit filed therewith, the High Court may becircumstances stated in the affidavit filed therewith, the High Court may bepleased to issue an appropriate writ, order or direction more particularly one in thenature of Writ of Mandamus, declaring the order passed by the lncome Taxnature of Writ of Mandamus, declaring the order passed by the lncome TaxAuthorities (National Faceless E-Assessment Centre) completed the assessmentUIS 147 read with section 1448 of the lncome{ax Act Date of 09/03/2024, DINUIS 147 read with section 1448 of the lncome{ax Act Date of 09/03/2024, DINITBA/AST/S/14712023-24t10622925a4(fior the Assessment Year 2O1g-2Odetermining the total income of Rs. 80,03,330/- as arbitrary, illegal, bad in law,without [jurisdiction, ]void-ab-initb, violative of the prirrciples of natural justice apartfrom being violative of Articies 14, t9(1Xg) and 265 of the Constitution of lndia andSec. lzl8A of the lncorne Tax Act, 1961 and consequently set aside the same inthe interests of justice.determining the total income of Rs. 80,03,330/- as arbitrary, illegal, bad in law,without [jurisdiction, ]void-ab-initb, violative of the prirrciples of natural justice apartfrom being violative of Articies 14, t9(1Xg) and 265 of the Constitution of lndia andSec. lzl8A of the lncorne Tax Act, 1961 and consequently set aside the same inthe interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Gounsel for the Respondent Nos. 1 & 2: Ms. J. SUNITHA, /-JUNIOR STANDING COUNSEL REPRESENTINGMs. SUNDARI R PISUPATI, SENIOR S.C. FOR INCOME TAX Counsel forthe Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR, /-DEPUTY SOLICITOR GENERAL OF INDIA WRIT PETITION NO: 11890 OF 2024 Between: Madhava Reddy Ganapathi, S/o. Narayana Reddy, Aged About 66 Years,Occupation. Business, R/O. Plot No.7 Hmt Sathavahana Nagar Colony, KukatpallyKukatpally Hyderabad 500072, Telangana, lndia PAN: AssessmentYear: 2018-19 ...PETITIONER ANO 1. Office of The lncome Tax Officer Ward15(1), Hyderabad, Telangana State. 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.P.,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028, _Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028, _Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Govemment of lndia, Secretariat Buildings,New Delhi - 1 10 001 .of Revenue, Ministry of Finance, Govemment of lndia, Secretariat Buildings,New Delhi - 1 10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5- The Union of lndia, Represented by its Secretary to the Govemment,Department of Revenue, Ministry of Finance, New Delhi - 1'10 001.Department of Revenue, Ministry of Finance, New Delhi - 1'10 001. ...RESPONDENTS 2. The Principal Chief Commissioner of lncome Tax - Telangana and A.P.,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028, _Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad - 500 028, _Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Govemment of lndia, Secretariat Buildings,New Delhi - 1 10 001 .of Revenue, Ministry of Finance, Govemment of lndia, Secretariat Buildings,New Delhi - 1 10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. 5- The Union of lndia, Represented by its Secretary to the Govemment,Department of Revenue, Ministry of Finance, New Delhi - 1'10 001.Department of Revenue, Ministry of Finance, New Delhi - 1'10 001. ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in thecircumstances stated in the affidavit filed therewith, the High Court may bepleased to issue an appropriate writ, order or direction more particulady one in thenature of Writ of Mandamus or any other appropriate Writ, Order, or Direction,declaring the order passed by the lncome Tax Authorities (National Faceless E-declaring the order passed by the lncome Tax Authorities (National Faceless E-Assessment Centre completed the assessment UIS 147 r/w Section 144-B of thelncome Tax Act, 1961 vide DIN and Notice No. dated O2tO3t2O24lncome Tax Act, 1961 vide DIN and Notice No. dated O2tO3t2O24ITBA/AST/S/14712023-2411061894657(1) for the assessmenr year 2O1B-19 determining the total income [of ][Rs. ][1,11,80,109/- ][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. ['148A ]of the Income Tax Act, [1961, ][and ][consequently set aside ][the ][same ][in]the interests of [justice, ]and [pass] Counsel for the Petitioner: SRI Counsel for the Respondent [Nos. ][1 ][& ][2: ][Ms. ][B. ] [REDDY']REPRESENTING SRI J. V. PRASAD, [S.C. FOR INCOME ] Counsel for the Respondent [Nos.3 ][to ][5: SRI GADI PRAVEEN KUMAR,]DEPUry SOLICITOR GENERAL OF WRIT PETITION NO: 11913 2024 [--''-] Between: SJP MOTORS, Rep by its [Partner, Jangam Jeevan, S/o.Gladstone--J?!S1T' ]Agedabout 40 [years, ]Oicuiation: [Business, Date ][of ][Formation: 21.09.2013' ][F/o. ][5 ][26]Ground Fl6or Laxmidevipalli [V, ][Main ][Road Kothagudem Mandal, Khammam ][5O71O1']Telangana, lndia. PAN: [Assessment Year: 2015-16] ...PETITIONER AND 1 . Office of The lncome [Tax Officer, ][Ward ]['l ], [Kothagudem, Telangana State] 2. The Principal Chief Commissioner [of ][lncome ][Tax ][Telangana ][and]A.P,Hyderabad, lT Towers, AC [Guards, ][Masab ][Tank, ][Hyderabad ][500]o28,TelanganaHyderabad, lT Towers, AC [Guards, ][Masab ][Tank, ][Hyderabad ][500]o28,Telangana 3. The Central Board of [Direct Taxes, Represented by its Chairman, Department]of Revenue, Ministry of Finance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 001 [.]of Revenue, Ministry of Finance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 001 [.] 4. The National Faceless Assessment [Center, ][lncome ][Tax ][Department, ][New]Delhi.Delhi. 5. The Union of lndia, Represented [by its ][Secretary ][to ][the ][Government,]Department of Revenue, [Ministry ][of Finance, New ][Delhi ]- [1'10 ][001]Department of Revenue, [Ministry ][of Finance, New ][Delhi ]- [1'10 ][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] 4. The National Faceless Assessment [Center, ][lncome ][Tax ][Department, ][New]Delhi.Delhi. 5. The Union of lndia, Represented [by its ][Secretary ][to ][the ][Government,]Department of Revenue, [Ministry ][of Finance, New ][Delhi ]- [1'10 ][001]Department of Revenue, [Ministry ][of Finance, New ][Delhi ]- [1'10 ][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 147 read with section 1448 ofthe lncome{ax Act Date of Order 13t03t2o24, DtN |TBA/AST/9I147t2023-Assessment centre) completed the assessment u/s 147 read with section 1448 ofthe lncome{ax Act Date of Order 13t03t2o24, DtN |TBA/AST/9I147t2023-2411062563921(1) for the Assessment Year 2015-16 determining the total incomeof Rs. 4,85,4301 as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio,violative of the principles of naturaljustice apart from being violative of Articles 14,t9(t)(g) and 265 of the Constitution of lndia and Sec. j48A of the lncomeTaxAct,1961, and consequently set aside the same in the interests of justice.of Rs. 4,85,4301 as arbitrary, illegal, bad in law, without jurisdiction, void-ab-initio,violative of the principles of naturaljustice apart from being violative of Articles 14,t9(t)(g) and 265 of the Constitution of lndia and Sec. j48A of the lncomeTaxAct,1961, and consequently set aside the same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR Counsel for the Respondent Nos. 1 & 2: Ms. B. SAPNA REDDY, [.--]REPRESENTING SRI J. V. PRASAD, S.C. FOR INCOME TAX Counsel for the Respondent Nos.3 DEPUTY to 5: SRI SOLICTTOR GADI PRAVEEN GENERAL OF INDIAKUMAR, ._ WRIT PETITION NO: 11915 OF 2024 Between: Sampath Kumar Thirukovela, S/o.Venkataiah, Aged about 62 years, Occupation:p^u9iqes1 .No. 1-2-51t10, Shasthri Nagar Niniat Near Ravt'SCnooL-nti66-aO504'1 06,Telangana, lndia. PAN : ABApT0866G Assessmen t y eac 201 6_1 7 . ...PETITIONER AND 1. Office of The lncome Tax Officer, Ward 1, Nirmal, Telangana State. 2. The Principa.l Ctrief Commissioner of lncome Tax - Telangana and A.P,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 028,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 028,Telangana. 3The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue,.Minis-try of Finance, Government of lhdia, secretariat riritoings,New Delhi - ['l ]10 001.of Revenue,.Minis-try of Finance, Government of lhdia, secretariat riritoings,New Delhi - ['l ]10 001. 4The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. I!:^YligL uepartment of [o.f^lndia, ]Revenue, Ministry of Finance, [Represented ][by ][its ]New Delhi [Secretary ]- i [to ]10 [the ]OO1 [Government,]. 5 ...RESPONDENTS 2. The Principa.l Ctrief Commissioner of lncome Tax - Telangana and A.P,Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 028,Telangana.Hyderabad, lT Towers, AC Guards, Masab Tank, Hyderabid - 500 028,Telangana. 3The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue,.Minis-try of Finance, Government of lhdia, secretariat riritoings,New Delhi - ['l ]10 001.of Revenue,.Minis-try of Finance, Government of lhdia, secretariat riritoings,New Delhi - ['l ]10 001. 4The National Faceless Assessment Center, lncome Tax Department, NewDelhi.Delhi. I!:^YligL uepartment of [o.f^lndia, ]Revenue, Ministry of Finance, [Represented ][by ][its ]New Delhi [Secretary ]- i [to ]10 [the ]OO1 [Government,]. 5 ...RESPONDENTS Petition under Article 226 of the Constitution of lndia [praying ]that in thecircumstances stated in the affidavit filed therewith, the High Court [may ]bepleased to issue an appropriate writ, order or direction more particularly one in thenature of Writ of lt/andamus declaring the order [passed ]by the 3rd [(National]Faceless E-Assessment Centre) completed the assessment U/S 147 read withsection 1448 of the lncome{ax Act Date of Order 16-03-2024, for the Assessment Year [2016-17]ITBA/AST/S/147t2O23-24t1O62772O40(1) determining the total income of Rs. 29,85,000/- 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(1 Xg) 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 Counsel forthe Respondent Nos. [1 ]& 2: Ms. J. SUNITHA,JUNIOR STANDING COUNSEL REPRESENTINGMs. SUNDARI R PISUPATI, SENIOR S.C. FOR INCOME TAX---Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN [KUMAR, ]DEPUTY SOLICITOR GENERAL OF INDIA WRIT PETITION NO: 11927 OF 2024 [<-] Between: Datta Annarao Deshaftiwar, S/o. Annarao Deshaftiwa, [Aged ][about ][52 ][years,]Occupation: Business, Rl/o. Flat No 301 Uma Enclave, [Ashoknagar ][Kakatiy_anqgar,]Ramihanarapuram, Medak 500032, Telangana, lndia. [PAN: ][ ]Assessment Year: 2018-1 9 ...PETITIONER AND 1. Office of the Assistant Commissioner of [lncome Tax ][Circlel2(1), ][Hyderabad]Telangana State.Telangana State. 2. The Principal Chief Commissioner of [lncome ][Tax ][- ][Telangana ][qlg ]&?,Hyderabad, lT Towers, AC Guards, Masab [Tank, ][Hyderabad ][- ][500 ][028']Telangana.Hyderabad, lT Towers, AC Guards, Masab [Tank, ][Hyderabad ][- ][500 ][028']Telangana. 3. 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 .of Revenue, Ministry of Finance, Government of [lndia, ][Secretariat Buildings,]New Delhi - 1 10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, New.Delhi.Delhi. 5. The Union of lndia, Represented by its Secretary to the Government,Department of Revenue, Ministry of Finance, New Delhi - 110 001 .Department of Revenue, Ministry of Finance, New Delhi - 110 001 . ...RESPONDENTS 3. 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 .of Revenue, Ministry of Finance, Government of [lndia, ][Secretariat Buildings,]New Delhi - 1 10 001 . 4. The National Faceless Assessment Center, lncome Tax Department, New.Delhi.Delhi. 5. The Union of lndia, Represented by its Secretary to the Government,Department of Revenue, Ministry of Finance, New Delhi - 110 001 .Department of Revenue, Ministry of Finance, New Delhi - 110 001 . ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in thecircumstances stated in the affidavit filed therewith, the High Court may bepleased to issue an appropriate writ, order or direction more particularly one in thenature of Writ of ttilandamus or any other appropriate Writ, Order, or Direction,declaring the order passed by the lncome Tax Authorities (National Faceless E-Assessment centre) completed the assessmenluls 147 read with section 144B ofthe lncome-tax Act Date of Order 26-02-2024, DIN |TBA/ASTlsl14tt2123-Assessment centre) completed the assessmenluls 147 read with section 144B ofthe lncome-tax Act Date of Order 26-02-2024, DIN |TBA/ASTlsl14tt2123-2411061491965(1)for the Assessment Year 2018-19 determining the total incomeof Rs. 49,05,1 1 0/- as arbitrary, itlegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles of natural justice apart from being violative ofArticles 14, 1 9(1 )(g) and 265 of the Constitution of lndia and Sec. 1484 of thelncome Tax Act, 1961 , and consequently set aside the same in the interests ofjustice.of Rs. 49,05,1 1 0/- as arbitrary, itlegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles of natural justice apart from being violative ofArticles 14, 1 9(1 )(g) and 265 of the Constitution of lndia and Sec. 1484 of thelncome Tax Act, 1961 , and consequently set aside the same in the interests ofjustice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR - Counsel forthe Respondent Nos. 1 & 2: Ms. B. SAPNA REDDY,REPRESENTING SRI J. V. PRASAD, S.C. FOR INCOME TAX Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERAL OF INDIA WRIT PETITION NO: 1 1939 0F 2024 Between: Ferozpasha Shaik, S/o. Gousepasha Shaik, Aged about 36 years, Occupation.Business, Fl/o. H No 18-5-9218 Maruthi Nagar, Godavarikhini Ramagdndam,Karimnagar 505209, Telangana, lndia [pAN: ]DDVpS7997p Assessment yeir:2O18_'19'19 ...PETITIONER AND '1 . Office of The lncome Tax Officer, Ward 2, Karimnagar, Telangana State 2. lhe Principal Chief Commissioner of lncome Tax, Telangana and A.p,Hyderabad, lT Towers, AC Guards, t\/asab Tank, Hyderabiad _ 5OO 028;Telangana.Hyderabad, lT Towers, AC Guards, t\/asab Tank, Hyderabiad _ 5OO 028;Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Governrnent of lhdia, secretariat duildings,New Delhi - 110 001.of Revenue, Ministry of Finance, Governrnent of lhdia, secretariat duildings,New Delhi - 110 001. 4. The National Faceless Assessment Center, Income Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represented by its Secretary to the Government,Department of Revenue, Ministry of Finbnce, New Delhi - 110 OO1.Department of Revenue, Ministry of Finbnce, New Delhi - 110 OO1. ,..RESPONDENTS 2. lhe Principal Chief Commissioner of lncome Tax, Telangana and A.p,Hyderabad, lT Towers, AC Guards, t\/asab Tank, Hyderabiad _ 5OO 028;Telangana.Hyderabad, lT Towers, AC Guards, t\/asab Tank, Hyderabiad _ 5OO 028;Telangana. 3. The Central Board of Direct Taxes, Represented by its Chairman, Departmentof Revenue, Ministry of Finance, Governrnent of lhdia, secretariat duildings,New Delhi - 110 001.of Revenue, Ministry of Finance, Governrnent of lhdia, secretariat duildings,New Delhi - 110 001. 4. The National Faceless Assessment Center, Income Tax Department, NewDelhi.Delhi. 5. The Union of lndia, Represented by its Secretary to the Government,Department of Revenue, Ministry of Finbnce, New Delhi - 110 OO1.Department of Revenue, Ministry of Finbnce, New Delhi - 110 OO1. ,..RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in thecircumstances stated in the affidavit filed therewlth, the High Court may becircumstances stated in the affidavit filed therewlth, the High Court may bepleased to issue an appropriate writ, order or direction more particularly one in thenature of Writ of Mandamus, declaring the order passed by the lncome TaxAuthorities (National Faceless E-Assessment centre completed the assessmentUIS 147 r/w Section 144-8 ot the lncome Tax Act, 1g61 vide DIN and Notice No.dated 1 3-1 2-2023 |rBA/AST lsl 1 47 12023- 241 1 o5B7 3s767 (1 ) for the assessmentyear 2018-19 determining the total income of Rs. 97,51,063/-as arbitrary, illegal,bad in law, without jurisdiction, void-ab-initio, violative of the principles of naturalUIS 147 r/w Section 144-8 ot the lncome Tax Act, 1g61 vide DIN and Notice No.dated 1 3-1 2-2023 |rBA/AST lsl 1 47 12023- 241 1 o5B7 3s767 (1 ) for the assessmentyear 2018-19 determining the total income of Rs. 97,51,063/-as arbitrary, illegal,bad in law, without jurisdiction, void-ab-initio, violative of the principles of naturaljustice apart from being violative of Artictes 1a, 19(1Xg) and 265 of theConstitution of lndia and Sec. 148A of the lncome Tax Act, 1961, andconsequently set aside the same in the interests of justice.Constitution of lndia and Sec. 148A of the lncome Tax Act, 1961, andconsequently set aside the same in the interests of justice. Counsel for the Petitioner: SRI THANNERU CHAITANYA KUMAR [,-] Counsel for the Respondent Nos. 1 & 2: Ms. J. SUNITHA,JUNIOR STANDING COUNSEL REPRESENTINGMs. SUNDARI R PISUPATI, SENTOR S.C. FOR INCOME TAx Counsel for the Respondent Nos.3 to 5: SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERAL OF INDIA The Court made the following: COMMON ORDER .---- THE HONOURABLE SRI JUSTICE SUJOY PAULAND THE HONOURABLE SRI JUSTICE N. TUI{ARAMJI WRIT PETITION NOs. 1183O11835 tLa46 tL847 11855118711189()11913I 1915 11927AND LL9390F20241189()11913I 1915 11927AND LL9390F2024 COMMON ORDER: (per Hon'ble Justice Sujog Paul) Sri Tharneru Chaitanya Kumar, learned counsel appears for the petitioner(s), Ms. B. Sapna Reddy, learnedcounsel representing Sri J.V. Prasad, learned Standing Counselfor the respondents-Income Tax Department in W.P.No.1l83O,11835, tI846, tt847, 11890, 11913 & 11927 of 2024 andMs. J. Sunitha, learned Junior Standing Counsel representingMs.Sundari R.Pisupati, learned Senior Standing Counsel for therespondents-lncome Tax Department in W.P.Nos. 1 1855, ILSZ l,11915 and 11939 of2024. Regard being had to being had to had to to the similarity of the questionsimilarity of the questionof the questionthe questionquestion 2Regard being had to being had to had to to the similarity of the questionsimilarity of the questionof the questionthe questionquestioninvolved, on the joint request of the parties, the matters areartalogously heard and decided by this common order. Regard being had to being had to had to to the similarity of the questionsimilarity of the questionof the questionthe questionquestion 2Regard being had to being had to had to to the similarity of the questionsimilarity of the questionof the questionthe questionquestioninvolved, on the joint request of the parties, the matters areartalogously heard and decided by this common order. 3. It is common ground taken by the learned counsel forthe petitioner(s) that in furtherance of Financ e Act, 2O2l , re-assessment process stood modified but the respondents have nottaken care of it and therefore notices issued under Section 14gof the Income Tax Act, 1961 cannot sustain judicial scrutiny. Since notices are bad in law, ,'n. .orr".Orential orders ar.'-"obad in l4w.bad in l4w. 4. During the course of hearing, learned counsel for theparties agreed that curtains on this issue are finally drawn bythis Court in a batch of writ petitions, W.p.No.25903 of 2022and other connected matters, decided by common order dated14.O9.2023. The parties agreed that this matter may be disposedof in terms of the Common Order dated 14.09 -2023. 5This Court in the said order dated 14.09.2023 inW.P.No.25903 of 2022, held as under: "35. ln view of the aforesaid discussions, it is by now very clear thatthe procedure to be followed by the respondent-Department upontreating the notices issued for teassessment being undel Sectionl/t84, the subsequent proceedings was mandatorily required to beundertaken under the substituted provisions as laid down under theFinance Act, 2021, ln the absence of which, we are constrained to holdthat the procedure adopted by the respondent-Department is incontravention to the statute i.e. the Finance Acl, 2O2,1, at the firstinstance. Secondly, it is also in direct contravention to th€ directivesissued by the Hon'ble Supreme Court in the case of Ashish Agarwal,supra.36. For all the aforesaid reasons, the impugned notices issued and theproceedings drawn by the respondent-Department is neither tenable,nor sustainable. The notices so issued and the procedure adoptedbeing per se illegal, deserves to be and are accordingly setasaderquashed. As a consequence, all the impugned orders gettingquashed, the consequential orde6 passed by the respondentOepa.tment pursuant to the notices issued under Section 117 and 18would also get quashed and it is ordered accordingly. The reason rveare quashing the consequential otder is on the principles that whenthe initiation of the proceedings itself was procedurally wrong, thesubsequent orders also gets nullffied automatically. -r- \ 37. The preliminary objection raised by the petitioner is sustained andall these writ petitions stands allowed on this very jurisdictional issue.Since the impugned notices and orders are getting quashed on thepoint of iurisdiction, we are not inclined to proceed further and decidethe other issues raised by the petitioner which stands reserved to beraised and contended in an appropriate proceedings.38. Since the Hon'ble Supreme Court had, in the case of AshishAgan /al, supra, as a one-time measure exercising the powerc underArticle 142 of the Constitution of lndia, permitted the Revenue toproceed under the substituted provisions, and this Court allotying thepetitions only on the procedural flaw, the right conferred on theRevenue would remain reserved to proceed further if they so wantfrom the stage of the order of the Supreme Court in the case of AshishAgarwal, supra.39. No order as to costs." 6. In view of the consensus arrived, the impugned Show Cause notices and consequential orders passed in this batch ofwrit petitions are set aside. Liberty is reserved to both the partiesto take respective stand and to proceed in accordance with lawas per paragraph No.38 of the order dated 14.09.2023 inW.P.No.25903 of 2022.writ petitions are set aside. Liberty is reserved to both the partiesto take respective stand and to proceed in accordance with lawas per paragraph No.38 of the order dated 14.09.2023 inW.P.No.25903 of 2022. 6. In view of the consensus arrived, the impugned Show Cause notices and consequential orders passed in this batch ofwrit petitions are set aside. Liberty is reserved to both the partiesto take respective stand and to proceed in accordance with lawas per paragraph No.38 of the order dated 14.09.2023 inW.P.No.25903 of 2022.writ petitions are set aside. Liberty is reserved to both the partiesto take respective stand and to proceed in accordance with lawas per paragraph No.38 of the order dated 14.09.2023 inW.P.No.25903 of 2022. The writ petitions are allowed. No costs. Interlocutory 7 applications, if any pending, shall also stand closed. SD/-A.V.S.PRASADASSISTANT REGIStrSI-ARb,SECTION OFFICER //TRUE COPY// To, 1. The lncome Tax'Officer Ward 9(1), Hyderabad, [Telangana ][State.] 2. The Principal Chief Cornmissioner of [lncome ][Tax ][Telangana]andA.P,Hyderabad, lT,lTowers, AC Guanls, Masab Tank, Hyderabad500o28,Telangana.Hyderabad, lT,lTowers, AC Guanls, Masab Tank, Hyderabad500o28,Telangana. 3. The Chairman, Department of Revenue, Ministry of Finance, Central Board ofDirect Taxes, Government of lndia, Secretariat Buildings, New Delhi - [1 ][10]001. IDirect Taxes, Government of lndia, Secretariat Buildings, New Delhi - [1 ][10]001. I 4. The National Faceless Assessment Cerrter, lncome Tax Department, NewDelhi.Delhi. 5. The Secretary to the Government, Department of Revenue, Union of lndia,Ministry of Finance, New Delhi - 110 001 .Ministry of Finance, New Delhi - 110 001 . 6. The lncome Tax'Officer, [Ward-15(1), Hyderabad, Telangana State] 7. The lncome [Tax Officer Ward ][4('1), ][Hyderabad/, Telangana State'] 8. The lncome [Tax ][Officer ][Wa ][rd 2 ][(1\' ][Hyderabad, Telangana State'] 9. The lncome [Tax Officer ][Ward ][1' Nizambad, Telangana State] 10. The lncome [tax ][officer ward 2, Karimnagar, Telangana State'] 11.The lncome [Tax'Officer, ][Ward ][1' Kothagudem, Telangana State] i'12. The lncome Ta( Officer, Ward 1 , Nirmal, Telangana [State] 1 3. The Assistant i [Commissioner ][of ][lncome ][Tax ][Circlel2(1 ][), ][Hyderabad]Telangana StateTelangana State 14.One CC to SRI [KUIVIAR' ][Advocate ][ ] '1 5.One CC to SRI i. IV. [pRnsRo, ]S.C. for [lncome Tax ] l6.oneCCtoSRlGAD|PRAVEENKUMAR,DeputySolicitorGeneraloflndialoPUCl ii:loPUCl ii:17.