Wp v. Office Of The Income Tax Officer

HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD(Special Original Jurisdiction) TUESDAY, THE SECOND DAY OF APRILTWO THOUSAND AND TWENTY FOUR PRESENT THE HONOURABLE SRI JUSTICE SUJOY PAULANDTHE HONOURABLE SRI JUSTICE N.TUKARAMJI WRIT PETITION NOs:8327 8335 8341 8416 AND 8423 0F 2024 WRIT PETITION NO: 8327 OF 2024 Between: l, SANDHYA RANI IVUKKARA, D/o. Ailallaiah Balakrishna Gotla, Aged About50 Years, Occupation Eusiness, R/o. H.No.2-2-185140 Rama Krishna Nagar,Bagh [Amberpet, Hyderabad 500013, Telangana, lndia. PAN ][ ]Assessment Y eat 201 5-1 6 ...PETITIONER AND IOffice Of The lncome Tax Officer Ward 9(1), Hyderabad, Telangana [State.] 2The Principal Chief Commissioner Of lncome Tax Telangana And [Ap,]Hyderabad, lT Towers, AC Guards, Masab Tank, HyderabadHyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad 3. The Central Board Of Direct Taxes, Represented By lts Chairman,Department of Revenue, Ministiy of Finance, Government of lndia, SecretariatBuildings, New DelhiDepartment of Revenue, Ministiy of Finance, Government of lndia, SecretariatBuildings, New Delhi 4. The National Faceless Assessment Center, lncome Tax [Department, ][New]Delhi.Delhi. 5. The Union Of lndia, Represented By [lts ][Secretary ][To ][The ][Government,]Department of Revenue, Ministry of Finance New DelhiDepartment of Revenue, Ministry of Finance New Delhi ...RESPONDENTS Petition under Article 226 of the Constitution of [lndia ][praying ][that ][in ][the]circumstances stated in the affidavit [filed ][therewith. ][the ]High [Court may ][be]pleased to issue an appropriate writ, order or direction more [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]UtS 147 r/w Section 144-8 [of ][lhe ][lncome Tax ][Act, ][1961 vide DIN and Notice ][No.]dated 05/03/2024 ITBA/ASTlsl14712023-2411062026065('1 ) [for the ][assessment] year 2015-l6determining the total income of Rs. 95,98,100/- as arbitrary, illegal,bad in law, wrthout jurisdiction, void-ab-initio, violatrve of the principles of naturaljustice apart from being violative of Articles 14, 19(1)(g) 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.bad in law, wrthout jurisdiction, void-ab-initio, violatrve of the principles of naturaljustice apart from being violative of Articles 14, 19(1)(g) 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. Counsel for the Petitioners: SRI T.CHAITANYA KUMAR Counsel for the Respondent No.1 & 2: SRI J.V.PRASAD, SC FOR TNCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REP. FORSRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 8335 OF 2024 Between: PALLEBOYINA MANJU RANI, W/o. Nagaiah, Aged About 56 years,Occupatron. Business, Rlo. 142l2RT H NO 10 -1 -4tB VTJAYANAGAROccupatron. Business, Rlo. 142l2RT H NO 10 -1 -4tB VTJAYANAGARCOLONY , MASAB TANK HYDERABAD 500057, Tetangana, tndia. pAN.BWFPM5l 88R Assessment Y ear. 2016-1 7BWFPM5l 88R Assessment Y ear. 2016-1 7 ...PETITIONER AND 1Office Of The lncome Tax Officer Ward 7(1), Hyderabad/, Telangana State.2The Principal Cfrief Commissioner of lncome Tax, Telangana and A.p,lyderabad, [lT ][Towers, ] [Guards, Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana.2The Principal Cfrief Commissioner of lncome Tax, Telangana and A.p,lyderabad, [lT ][Towers, ] [Guards, Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana. JThe Central Board of Drrect Taxes, Represented by its Chairman, Departmentof Revenue, Ivlnistry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 1'10 001.of Revenue, Ivlnistry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 1'10 001. ...PETITIONER AND 1Office Of The lncome Tax Officer Ward 7(1), Hyderabad/, Telangana State.2The Principal Cfrief Commissioner of lncome Tax, Telangana and A.p,lyderabad, [lT ][Towers, ] [Guards, Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana.2The Principal Cfrief Commissioner of lncome Tax, Telangana and A.p,lyderabad, [lT ][Towers, ] [Guards, Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana. JThe Central Board of Drrect Taxes, Represented by its Chairman, Departmentof Revenue, Ivlnistry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 1'10 001.of Revenue, Ivlnistry of Finance, Government of lndia, Secretariat Buildings,New Delhi - 1'10 001. 4The National Faceless Assessment Center, lncome Tax-- Department, NewDelhi.Delhi. 5The Union oJ_lndia, Represented by its Secretary to the Government,Department of Revenue, lvlinistry of Finbnce, New Delhi - 1 [-10 ]OO1 .Department of Revenue, lvlinistry of Finbnce, New Delhi - 1 [-10 ]OO1 . ...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 inthe nature of writ of declaring the order passed by the lncome Tax Authoritiescircumstances stated in the affidavit filed therewith, the High Court may bepleased to issue an appropriate writ, order or direction more particularly one inthe nature of writ of declaring the order passed by the lncome Tax Authorities(National Faceless E-Assessment centre completed the assessment U/S 147 rlw Section 144-8 of the lncome Tax Act, 1961 vide DIN and Notice No. datedlncome Tax Act, 1961 vide DIN [and ][Notice ][No. ][dated ][2810212024]fot the assessment [year ][2O16-]ITBA/AST/S/147/2023-24/1061633174(1) l Tdetermining the total income [of ][Rs. 55,38,910/- ][as ][arbitrary, illegal, ][bad ][in law,]without [jurisdlction, ]void-ab-initio, [violative ]of [the ][principles ][of ][natural justice]apart from being violative of [Articles 14, ][19(1)(g) ][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: [T.CHAITANYA ] Counsel for the Respondent [No.1 ][& 2: ] [J.V.PRASAD, ] Counsel for the Respondent [No.3 ][to ][5: ] [B.MUKHERJEE, ][REP. ] SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 8341OF [2024] Between: l, Mohammed Abdul Rahman, [S/o ][N4ohammed ][Abdul ][Raheem,-aged. about 72]vears, Occupation [Business, ][Rlo ][1-10-7914 ] [Gutta, ][Mahabubnagar]i;OSOOt ,tetangana, lndia. PAN [Assessment ][Year ][201 ][5-16] ...PETITIONER AND 1.Office Of The lncome Tax Officer [Ward, ],lVlahabubnaga [r, ][Telangana ][State.] 2.The Principal Chief Commissioner of [lncome ][Tax, ][Telangana ]9!q |.?,Hyderabad, lT Towers, AC Guards, [Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana.Hyderabad, lT Towers, AC Guards, [Masab ][Tank, ][Hyderabad ][- ][500 ][028,]Telangana. JThe Central Board of Direct [Taxes, Represented ][by its ][Chairman, Department]of Revenue, Ministry of Flnance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 [001 ][.]of Revenue, Ministry of Flnance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 [001 ][.] 4The National Faceless Assessment [Center, ][lncome ][Tax ][Department, ][New]DelhiDelhi 5The Union Of lndia, Represented [By ][lts ][Secretary ][To ][The ][Government,]Department of Revenue, [Ii/inistry of Finance, New ][Delhi-1 ]['10001 ][.]Department of Revenue, [Ii/inistry of Finance, New ][Delhi-1 ]['10001 ][.] ...RESPONDENTS JThe Central Board of Direct [Taxes, Represented ][by its ][Chairman, Department]of Revenue, Ministry of Flnance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 [001 ][.]of Revenue, Ministry of Flnance, [Government ][of ][lndia, ][Secretariat Buildings,]New Delhi - 110 [001 ][.] 4The National Faceless Assessment [Center, ][lncome ][Tax ][Department, ][New]DelhiDelhi 5The Union Of lndia, Represented [By ][lts ][Secretary ][To ][The ][Government,]Department of Revenue, [Ii/inistry of Finance, New ][Delhi-1 ]['10001 ][.]Department of Revenue, [Ii/inistry of Finance, New ][Delhi-1 ]['10001 ][.] ...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 [\rlandamus declaring the order [passed ]by the 3rd (NationalFaceless E-Assessment Centre) completed the assessment U/S 147 read withsection 1448 of the Income-tax Act Date of Order 2310312024, DINITBA/AST/S/14712023-2411063285992(1) for the Assessment Year 2015-'l6determining the total income of Rs. 38,14,275l- 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)(g) and 265 of the Constitution oflndia and Sec. ['148A ]of the lncome Tax Act, 1961 , and consequently set asidethe same in the interests of [justice.] Counsel for the Petitioner: SRI T.CHAITANYA KUMAR Counsel for the Respondent No.1 & 2: SRI J.V.PRASAD, SC FOR INCOME TAX Counsel for the Respondent No.3 to 5: SRI B.MUKHERJEE, REP. FORSRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERIAL OF INDIA WRIT PETITION NO: 8416 OF 2024 Between: Sri Kanaka Durga Restaurant, Rep. by its partner Sanem Sudhakar Goud S/o.Sudarshan Goud, aged about 63 years, Occ Business R/O House No 8 134,Koheda Village, Hayathnagar [Vlandal Rangareddy 501511, Telangana, lndia.Pan Assessment Year 20'1 5- 16 ...PETITIONER AND 1Office of The lncome Tax Officer, Ward 15(1), Hyderabad, Telangana State. 2The 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 Government,Department of Revenue, [/]inistry of Finance, New Delhi - 110 001 .Department of Revenue, [/]inistry of Finance, New Delhi - 110 001 . ...RESPONDENTS Petition under Article 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 ][(National]Faceless E- Assessment Center) completed [the assessment ][UiS ][147 ][read with]section 1448 of the lncome- tax Act [Date ][of ][Order ][01- 02- ][2024 ]' ITBA/AST/S/147t2O23- 2411060398680(1) [for ][the ][Assessment ][Year 2015- ][16]determining the total income [of ][Rs. 26,98,794l- as arbitrary, illegal, ][bad ][in ][law,]without [jurisdiction, ]void- ab- [initio, ][violative ][of the ][principles ][of ][natural ][justice]violative of Articles [1a, ][19(1)(g) ][and 265 of ][the ][constitution of]apart from being 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 [T.CHAITANYA ] Counsel for the Respondent [No.1 ][& ][2: ] [J.V.PRASAD, ] Counsel for the Respondent [No.3 ][to ][5: SRI ][B.MUKHERJEE' ][REP. ] SRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERIAL WRIT PETITION NO: 8423 Between: Nagaraju Kashappa, S/o. - [Govind ][Kashappa ][Ag^e^qb!.uJ ][40 Years, ][O99yP3l'.9I']B,;h"(., NIO. [. ]S-S-I I ZIS, SRINAGAR [COLONY, ][RAMANTHAPUR']fli-Oenn'eno, 500013, [Telangana ] [CWUPK83134 Assessment ][Year]2015-16 ...PETITIONER AND 1Office of The lncome [Tax Officer, ][Ward ]['16(3), ][Hyderabad, Telangana ][State] 2The Principal Chief [Commissioner ][of ][lncome ][Tax ][Telangana ][and]A.P,nvOeraUaOi lT Towers, [Guards, ][Masab ][Tank, ][Hyderabad ][500]o28,TelangananvOeraUaOi lT Towers, [Guards, ][Masab ][Tank, ][Hyderabad ][500]o28,Telangana 3. ' The central Board [of ][Direct ][Taxes, Represented by ][its ][chairman, ][De_Partment]6i n"*nr", Vinistry of Finance, Gov6rnment of lhdia, Secretariat Buildings,New Delhi [- ]110 [001]6i n"*nr", Vinistry of Finance, Gov6rnment of lhdia, Secretariat Buildings,New Delhi [- ]110 [001] 4. The National [Faceless Assessment ][Center' ][lncome ][Tax ][Department, ][New]DelhiDelhi 5. The Union of [lndia, ][Represented ][by ][its ][Secretary ][t9 ]!h9^ [Government']- Oepart.ent of Revenue, Ministry of Finbnce, New Delhi - '1 10 001- Oepart.ent of Revenue, Ministry of Finbnce, New Delhi - '1 10 001 ..,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 inthe nature of Writ of Mandamus or any other appropriate Writ, Order, orDirection, declaring the order passed by the respondent no 1 completed theassessment UIS 147 read with section 1448 of the lncome-tax Act Date of Order21 lO3l2O24, DINITBA/AST/SI 1 47 12023 - 241 1063082302(1 )lor the AssessmentYear 2015 - 16 determining the total income of Rs_ 36,12,903/- as arbitrary,illegal, bad in law, without jurisdiction, void-ab-initio, violative of the principles ofnatural, justice apart from being violative of Articles 14, 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. Counsel for the Petitioner: SRI T.CHAITANYA KUMAR Counsel for the Respondent No.1 & 2: SRI J.V.PRASAD, SC FOR INCOME TAX counsel for the Respondent No.3 to 5: sRl B.MUKHERJEE, REp. FoRSRI GADI PRAVEEN KUMAR,DEPUTY SOLICITOR GENERIAL OF INDIA The Court made the following: COMMON ORDER THE HONOURABLE SRI JUSTICE SUJOY PAULANDTHE HONOURABLE SRI JUSTICE N. TUKARAMJI WRIT PETITION NOS.8327, 8335, [8341, ][8416 ] a423 0F 2024 COMMON [ (per ][Hon'ble ][SP,J)] Heard Sri T.Chaitanya Kumar, [learned ][counsel ][for ][the] petitioner(s), Sri J.V.Prasad, [learned ][Standing Counsel ][for]Income Tax appearing [on ][behalf ][of ][respondent ][Nos.1 ][and ][2, ][and]Sri B.Mukherjee, [learned counsel representing ][Sri ][Gadi ][Praveen]Kumar, learned [Deputy Solicitor ][General ][of India ][appearing ][on]behalf of [respondent ][Nos.3 ][to ][5.] Regard being had to the similarity had to the similarity to the similarity similarity [[of ][the ][question]][[the ][question]][[question]] 2. Regard being had to the similarity had to the similarity to the similarity similarity [[of ][the ][question]][[the ][question]][[question]]involved, on the [joint ][request ][of ][the ][parties, ][the ][matters ][are]analogously heard [and ][decided ][by ][this ][common order.] It is common is common common ground taken by the the [[learned ][counsel for]][[counsel for]] Regard being had to the similarity had to the similarity to the similarity similarity [[of ][the ][question]][[the ][question]][[question]] 2. Regard being had to the similarity had to the similarity to the similarity similarity [[of ][the ][question]][[the ][question]][[question]]involved, on the [joint ][request ][of ][the ][parties, ][the ][matters ][are]analogously heard [and ][decided ][by ][this ][common order.] It is common is common common ground taken by the the [[learned ][counsel for]][[counsel for]] 3. It is common is common common ground taken by the the [[learned ][counsel for]][[counsel for]]the petitioner(s) [that ][in ][furtherance ][of ][Finance ][Act, ][2021, ][te-]assessment [process ][stood ][modified ][but ][the ][respondents have ][not]taken care of it and [therefore notices issued ][under ][Section ][148]of the Income Tax Act, [196 ]I [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 counsel for theparties agreed that curtains on this issue are finally drawn bythis Court in a batch of writ petitions, W.p.No.259O3 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.O9.2023. 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 uponthe procedure to be followed by the respondent-Department upontreating the notices issued for reassessment being under Section148A, the subsequent proceedings was mandatorily required to be148A, 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 ate constrained to holdthat the procedure adopted by the .espondent_Department is inthat the procedure adopted by the .espondent_Department is incontravention to the statute i.e. the Finance Act, ZOZ1, at the firstinstance. Secondly, it is also in direct contravention to the directivesissued by the Hon'ble Supreme Court in the case of Ashish Agarwal,su pra.su pra. r.. r../ [36. ][For all the ]aforesaid reasons, the impugned notices issued and fheproceedings 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 setaside/quashed. As a consequence, all the impugned orders gettingquashed, the consequential orders passed by the tespondentOepartment pursuant to the notices issued under Section 147 and i4gwould also get quashed and it is ordered accordingjly. The reason weare quashing the consequential order is on the principles that whenthe initiation of the proceedings itself was procedurally wrong, thesubsequent orders also gets nullified automatically.37. The preliminary objection raised by the petitioner is sustained andall!hese writ petitions stands aflowed on this very iurisdictionar issue. .+' Since the impugned notices and orders are getting quashed on thepoint of jurisdiction, 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 AshishAgarwal, supra, as a one-time measure exercising the powers unde.Article 142 of the Constitution of lndia, permitted the Reyenue toproceed under the substituted provisions, and this Court allowing 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 ordea as to costs." .+' Since the impugned notices and orders are getting quashed on thepoint of jurisdiction, 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 AshishAgarwal, supra, as a one-time measure exercising the powers unde.Article 142 of the Constitution of lndia, permitted the Reyenue toproceed under the substituted provisions, and this Court allowing 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 ordea as to costs." 6In view of the consensus a-rrived, the impugned ShowCause notices and consequential orders [passed ]in this batch [of]writ 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 [rn]W.P.No.25903 of 2022 7 . The writ petitions are allowed. No costs. Interlocutoryapplication-s, if any pending, shall a-lso stand!19!gg,_ SD/. V. HARI PRASDASSISTANT REGISSECTION OFFICER D //TRUE COPY// To, 1The Office Of The Income Tax Officer Ward 9('l), Hyderabad, TelanganaState.State. 2The Office Of The lncome Tax Officer Ward 7( 1), Hyderabad/, TelanganaState.State. 3. The Office Of The lncome Tax Officer Ward,Mahabubnagar, TelanganaState.State. 4. The Office of The lncome Tax Officer, Ward 15(1), Hyderabad, TelanganaState.State. 5. The Office of The lncome Tax Officer, Ward [16(3), ][Hyderabad, Telangana]State.State. 6 The Princip{ _Chief Commissioner Of lncome Tax Telangana And Ap,-Hyderabad, lT Towers, AC Guards, Masab Tank, HyderabadHyderabad, lT Towers, AC Guards, Masab Tank, Hyderabad7. The chairman, centrar Board of Direct Taxes, Department of Revenue,lr,4inistry of Finance, Government of rndia, Secretariat aLiroingi, Ne* D;ihi [-'']lr,4inistry of Finance, Government of rndia, Secretariat aLiroingi, Ne* D;ihi [-'']8. The National Faceless Assessment center, rncome Tax Department, NewDelhi.Delhi.9. The Secretary_ to The Gorrernment, Department of Revenue, Ministry ofFinance, New Delhi, Union Of lndia.Finance, New Delhi, Union Of lndia.'10. One CC to SRI T.CHA|TANYA KUN/AR, Advocate tOpUCl11. One CC to SRI J.V.PRASAD, SC FOR TNCOME TAX tOpUCl12.one cc to sRl GAD| pRAVFf N KUMAR, DEpury solrcrroR GENERTALOF tNDtA. High Court for the Stare of tetanganaii HyaeiaOao lOpUEit'"'11. One CC to SRI J.V.PRASAD, SC FOR TNCOME TAX tOpUCl12.one cc to sRl GAD| pRAVFf N KUMAR, DEpury solrcrroR GENERTALOF tNDtA. High Court for the Stare of tetanganaii HyaeiaOao lOpUEit'"'1 3. Two CD CopiesBSRGJPGJP HIGH DATED: [o2lo4l2024] COMMON WP.Nos'8 [327,8335,8341' ][8416 ] [8423 OF 2024] (-[o][R][ iHE ] [ ,6.]os([ 5 iirl 2024'4.*"4 [' ][,;iiE-O] ALLOWING [WRIT PETITIONS']WITHOUT