Allowed

M/s. Mohammad Zakir Ali v. The National Faceless Assessment Centre

Telangana HC3 Jul 2025WP/18853/2025

Case brief

AI extract

What is this about?

Assessee challenged reassessment notices and order issued non-facelessly in violation of the Finance Act, 2021 faceless scheme. Following Kankanala Ravindra Reddy and other High Court decisions, the court quashed the notices and consequential orders, subject to outcome of pending SLPs.

What did the court decide?

Impugned notice under Sections 148-A and 148 and consequential reassessment order set aside/quashed; no costs.

M/s. Mohammad Zakir Ali Vs The National Faceless Assessment… — Income Tax | Telangana HC (2025)

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13447^|

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HrGH couRr^t?T IIE:[tliDoF rE:ANGANA (SPeciai^{Original Jurisdiction)}

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THURSDAY,^{THE THIRDDAYOF JULY} rWO iTIOUSNND^{AND TWENTYFIVE}

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PRESENT

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THE HONOURABLE^{SRI JUSTICEP'SAM KOSHY}

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THE HONOURABLE^{SRIJUSTICE NARSINGRAONANDIKONDA}

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WRIT^{PETITION NO:18853OF2025}

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Between:

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tr,4/s. Mohammad^{Zakir Ali,.S/o MohammedMahbub'Ali' Aged about 60 Years'1-1-} lliiiia' itoir^{lincAR,Mahabubnagar'Telansana'I nd ra'}

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.....PETITIONER

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AND

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The^{National FacelessAssessment Centre' lncome-tax Department'New} Delhi,^lndia.

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lncome^{Tax Officer, Ward1} '^{Mahabubnagar' Telangana'}

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1 The Assessment^{Unit,lncomeTaxDepartmentMinistryof Finance'}

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" c"r"i"r""t of lndia, New Delhi'

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.....RESPONDENTS

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Petition^{UnderArticle 226 oI the Constitutionof lndia praying that in the} circumstances^{stated in the affidavit filedtherewith' the HlOh Cgul may} ,!: ':' ier oi Olrection' more particularly^{in the nature of writ of} pleased to issue^{a wrlt'or(} mandamus^{declaring order under Section148A(d)dated30-03-2024bearing} |rBA/AST/F/14^{8Ar2023-24t1063670054(1),the notice dated 30-03-2024urs. 148} bearing DIN^{ITBA/ASTtsl148 I t2o23-2411}63672374(1)and the Reassessment} orderdated25-12.2024bearingDlNITBA/ASTtst147t2o24.25/1071556308(1), as being^{void, illegal'arbitrary, without jurisdiction' violateof Article 14 of the} Constitution^{of lndia and consequently set aside the same'}

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l.A.NO:1 oF 2025

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Petition under section 15'1 cPC praying that in the circumstances stated in the affidavit fired in support of the writ petition, the High court may be preased to stay arr further proceedings inciuding coirection of tax pursuant to the Reassessment order 25-12-2024 bearing DrN ,rBA/AST/S/14 7/202425l1071s56308(1)

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Counsel for the petitioner : SRI M.NAGA DEEPAK

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fiilt"' for the Respondents : sRt K.suDHAKAR REDDY (sr sc FOR tNcoME

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The Court made the foltowing ORDER

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THE HONOURABLE^{SRIJUSTICEP'SAM KOSHY} AND THE HONOURABLE^{SRTJUSTICENARSING RAO} NANDIKONDA

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WRIT PE^{TITION No.18853 of2025}

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ORDER,^{(per Hon'ble Sri 'lustice NarsingRao Nundikonda)}

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Heard Mr.M'Naga^{Deepak' leamed counselfor the} petitioner^{and Mr'K'sudhakar Reddy'learned Senior Standing} Counsel^{for the lncome Tax Departmentappearing for the} respondents.^{Perusedthe record'}

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This is^{a writ petitionwhere the proceedingsare either} challenged^{to the notices whichwere issuedunderSection 148A} andl48oftheIncome,faxAct,lg6l(forshort.theAct,)orthe assessmentordersthosehavebeenpassedunderSectionl4Tof the Act^{whichhavebeen assailed'}

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This writ^{petition is being takenup todayonlyon one of the} grounds, that^{the noticesissuedunder Section 148A of the Act} and the subsequent^{initiation of proceedings under Section148 of} the Act by the^{jurisdictional AssessingOfhcer' whereasin terms} of the amendment^{that was broughtto the IncomeTax Act by way} of Financeldt,^{2021w.e.f., 01.04.2021 onwards, proceedings}

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under Section l4gA of the Act as also under Section l4g of the Act ought to have also been issued and proceeded in a facelcss. manIler.

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The contention of the petitioner is that the issue ol proceedings being in violation of the Financ e Act, 2021 i.e., the impugned notices under Section l4gA and Section 14g of the Act not being issued in a faceless manner, have already been dealt with and decided by this Court in the case of KANKANALA RAVINDRA REDDY vs. INCOME_TAX OFFICERT decided on 14.09.2023 whereby a batch of writ petitions were allowed and the proceedings initiated under Section l4gA as also under Section 148 of the Act wer.e held to be bad with consequential reliefs on the ground of it being in violation of the provisions of section 151A of the Act read with Notification lBlZO22 dated 29.03.2022. The said judgment passed by this court has arso bee, subsequentry foilowed in a large number of writ petitions which were allowed on simirar terms

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'[(2023) 156 raxmann.com l7g (Telangana)]

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)

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Down the^{line, we find that the same issue has also been} decided against^{the Revenue by various High Courts i'e"} by the^{BombayHigh Coufi in the case of HEXAWARE} 'IECHNOLOGIES LTD', vs' ASSISTANT^COMMISSIONER oF INCOME^{TAx & OTHERS2,GauhatiHigh Couttin the case} of RAM NARAYAN^{SAH vs' UNIONOF INDIAT' Punjab and} lJaryana^{High Court in the caseof JATINDER SINGH BANGU} vs. UNION^{OF INDIA4,and TelanganaHigh Court in thecase of} SRI VENKATARAMANA^{REDDY PATLOOLA VS. DEPUTY} COMMISSIONER^{OI'' INCOME TAX5 where the issue was in} respect of^{international taxation, Bombay High Court in the case of} ABHTN ANILKUMAR^{SHAII vs' INCOMETAX OFFICER'} INTERNATI0NAL^{TAXATION6which is againon intemational} taxation^{and central circte, High Court of HimachalPradesh in the} case of GOVIND^{SINGH vs' INCOMETAX OFFICERT,} Guj arat High^{Court inthe caseof} MANSUKHBHAI

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'lzoz+1464^{ITR 430 (Bom)}

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'iQOzq^{156 taxmann.com 478 (Gauhati)l} 'l(2024)^{l651aimrinri.'i6m 115 (Ptiniab & Haiya-rid)l ' -}

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'12024)¹⁶⁷ [axmann.com^{4i 1 (Telangana)]}

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" L2024)^{166 taxmann.com 6T9 (Bombay)l}

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'12024)¹⁶⁵ taxmann.com^{113 (Flimachal Pradesh)l}

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DAIIYABHAI RADADIYA vs. tNCoME TAx OFFICER, WARD 3(3Xr8, Jharkand High Courr in the case of SIIyAM SUNDAR SAW vs. UNION OF INDIAe, Rajasrhan High Courr in the case of SHARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER and batch of writ petirionsr0 which stood decided on 19.03.2024. Similar views have also been taken by the Division Bench of Calcutta High Court in rhe case of GIRDHAR GOPAL DALMIA vs. UNION OF INDIA & ORS (M.A.T 1690 ot2023), decided on25.09.2024.

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Even though the same issue having been decided by a large number of High Courts, we are still confronted with large filing of identical matters on daily basis ranging between 5 to 10 writ petitions. That upon the instructions being sought from the Department, they have been taking a solitary ground that the decision of the Bombay High court in the case of Hexaware Technologies Ltd., (2 supra) as also the one which has been decided by this Courl in the case of Kanakala Ravindra Recldy

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82024 SCC Online Gg 4012

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" 2025 Scq.-Otl{-inc Jhar 287 'u 720^{23 :} RI-JD:49g4_DB I

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(1 supra) has^{beensubjectedto ohallenge in a SpecialLeave} Petition i.e.,^{SLPNo.3574of 2024 beforethe Hon'bleSupreme} Courl and^{the Hon'bleSupreme Court is seized of the matter'} In addition,^{there are about 1200 SLPs also frled arising out of the} same issue^{being decided by variousHighCourts'}

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To a^{query beingput to the learned counselfor the Revenue'} they have^{categoricallyaccepted the fact that there is no interim} order granted^{by the Hon'ble Supreme Court in any of these} matters^{pending before it'Meanwhile' fresh writ petitions of} identicat^{natureare beingpiled up belore this Bench on dailybasis} and the^{pendency is getting increasedon matter which otherwise} has already^{been dealt anddecided by this veryHigh Court itself'}

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On the^{one hand, even thoughthe order of this Court that} was passed^{as early as on 14'09'2023 and more 16 monthshave} lapsed, till^{date, we do not find any remedialsteps havingbeen} taken by^{the Income Tax Departmentto take appropriatesteps to} either hotd^{back issuance of notice under Sectionl48A and under} Section^{148 of the Act by the jurisdictionalAssessingOfficer'} rather the authorities^{concemed in the teeth of seriesof decisions}

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by all the major High Courts in India are continuously still initiating proceedings under Section 14gA of the Act and also initiating pr.oceedings under Section l4g of tl.re Act in contravention to the amenclnents brought into the Income .fax Act pursuant to the Finance Act,2020 as arso the Finance Acr 2021 .

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9' Upon a query being put as to why can,t this writ petition be disposed of in the teeth of the decision rendered by this Courl in the case of Kanakala Ravindra Reddy (I supra), Ieamed Standing Counsel for the Income Tax Depaftment contends that those would unnecessarily burden the Income Tax Deparlment where they would be required to file equal number of s]-ps before rhe Hon'ble Supreme Court and it would be further burdening the exchequer of the Union of India. It was also the contention of the leamed Standing Counsel that no prejudice would be caused to the interest of the petitioners in case if this rvrit petition is kept pending till the finalization of the SLps pending before the Hon,ble Supreme Court and the fact that the petitioner is already enjoying the benefit of interim protection. Nonetheless, on the earlier query olthis Court as to why the Income Tax Department have not come out with a mecl-ranispr to issue appropriate instructions or to take f

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'il

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appropriate^{stepsin ensuringthatproceedingsunder Section 148,{} of the Act^{as alsothe assessment orders underSection148 of the} Act are kept^{in a hold in the light ofthe decisions dedcided by the} various High^{Courts, it was submitted by the leamedStanding} Counsel^{that the said steps can only be taken at the level ofCBDT} as any such^{steps wouldhave to be taken Pan Indiaand cannot be} timited to^{any of thesejurisdictional HighCourts'}

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As^{a result of which,what we are facing is steep increaseof} litigation^{day in and day out even though various orders have been} passed by this^{High Courtallowing writ petitionson the very same} issue. The^{Income 'l'ax authorities concernedare still even now in} 2025 also^{initiating proceedings in contraventionto the provisions} of Section^{151Aof the Act and as a result by now' more than 600} to 700^{petitionshave beenalready got piled up beforethis High} court on^{an issuewhichotherwise stands squarely coveredby the} judgment of this^{Courtin the case of Kanokolu Ravindra Reddy} (1 supra). What^{is also surprising is the fact that though while} allowing^{the writ petitionsin the case of Kanakala Ravindra} Reddy (l^{supra), the DivisionBench whilereservingthe right of} the Revenue,^{has also protected the interest of the petitioners}

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insofar as the liberty which was granted to the Revenue for initiating fi.esh proceedings strictly in accordance u,ith the amended provisions of the Act, as amended by the Finance Act, 2020 and the Finance Act,202r. The petitioner assessee would be entitled to challenge or raise the other legal objections if the Reven,e initiates fresh proceedings. The Department has made no endeavour in availing the said liberty that was reseled for thc Revenue. On thc contrary, they have been still sticking on to the stand, which fhis High Court as well as rnany other Higlt Courts already held to bc bad.

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It appears that because of the aforesaid liberty rhat this I{igh Court had granted permitting the Revenue for initiating fresh proceedings as a one-time measure in a faceless manner, the Income Tax Department wants to take advantage of.thc same by protracting these proceedings which would enable them to meet the limitation that would otherwise come in the way. Likervise, if the writ petition is kept pending for a considerable long period of time and finally at a later stage if the Hon,ble Supreme Court confirrrs -;-'-.-'; -- the decision taken by ttiii niltr-doiit ds ilso br-tti; oirrii Histl Courts in which the SLps are still pending, the Income Tax I ('

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Department^{would get the advantageof the libefiy that is otherwise} protected in^{favour of the Revenue for initiation of fresh} proceedings^{from the disposatofthese matters at a much later stage} which would^{be advantageousand beneficial to the Revenue and} would be^{equally disadvantageous and detrimentalso far as interest} of the assesses^{are concemed' As a consequence'the Income Tax} . Department^{gets an extendedperiodof time for initiationof fresh} proceedings.

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The^{alarming trend of docketexplosion in this Court' despite} the clear^{precedentset in Kanakala Ravindra Reddy(l supra)' is a} matter^{of grave concern' The Income Tax Department's persistent} initiation^{of fresh proceedings' disregarding the established judicial} pronouncements,^{has led to an unprecedentedsurge in litigation} with over^{600-700 petitionspiling up on the same issue'This} deliberate^{approach not onlyundetmines the principle of judicial} precedent^{but also strainsthe judicialresources unnecessarily' The} Departmenf^{s strategyof awaiting the Supreme Court's decision on} pending SLPs^{while continuingto initiate fresh proceedings} appears to^{be a calculated move to buy time and circumvent} limitation^{periods, rather than adhering to the establishedlegal}

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position. Such conduct raises serious questions about the administrative efficiency and the respect for judicial pronouncements, parlicularly when this court has already provided a balanced approach by preserving both the Revenue,s rights and assesses lnterests.

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Another aspect which needs to be considered is that in fact it should have been realized by the Income Tax Department itself and should have found out via media in ensuring thal proccedings under Sections l4g_A and l4g should not have been issued in a faceless manner, at least till the Hon,ble Supreme Court decide the twelve hundred (1200) odd SLps which it is arready seized ofor, at least the Income Tax Deparlment should have ibund out some remedial steps to ensure that wherever the authorities intend to initiate proceedings under Sections l4g_A and l4g, other than in a faceless manner, the proceedings should have been deferred without precipitating the matter fuither intimating the assessee that they shail initiate appropriate proceedings only after the SLp,s are decided by the Hon,ble Supreme Court on the very same issue. This again, the lncome Tax Department, has not been able to give a convincing reply, except for the fact that such a decision if at all n

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has to^{be taken, hasto be taken for the whole of India' and which} otherwise^{has to be by way of a policydecision and that too at the} level of^{Central Board of DirectTaxes' Thoughthe leamed} Standing^{Counselfor the IncomeTax Departmentcontendedthat} the Delhi^{HighCourt dismisseda writ petition of similar nature' on} the one^{hand when the High Court is strugglingto reduce its} pendency,^{such noticeswhichare under challenge in this writ} petition^{are forcing the assessee to knock the doors of this High} Coud^{resultingin filing of hundreds of new writ petitionswhich in} the long^{run not only affects the disposalof the writ petitionsbut} also^{consumes substantialtime of the Bench in hearingthese} matters^{again and again on daily basis' Admittedty' in spite of the} rnatterbeforetheHon'bleSupremeCourlhavingbeentakenon many occasions,^{the Hon'bleSupremeCourt whichis seized of the} matter has^{beenreluctantin grantingany interim protection to the} Income^{Tax Department'Yet' the authoritiesconcernedat the} State level^{are not ready to acceptthe verdict passed by a majority} of High Courts^{of differentStates on the sameissue; and to make} things^{further worse, the Income Tax Departmentis showing} audacity^{by issuing noticescontinuouslyunderSections 148-4 and}

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-t2

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148 through the jurisdictional Assessing Officer whereas it ought to have been only in the faceless manner.

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[n thc case of BANK OF INDIA vs. ASSISTANT COMMISSIONER, INCOME TAXu, on un ir.r" whether ir was .justifiable on the part of the Incorne Tax Department in not following an order passed by the adjudicating authority only on the ground that the appeals are pending, the Division tsench of the High Court of Bombay held at paragraph No.25 as under, viz., :

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'25. Mr.^paridwalla has righfly drawn out attention to the decision of this Court in Commissioner of lncome Tax vs. Smt. Godavaridevi Sarafl2 as also the recent decision of the coordinate Bench of this Court in Samp Furniture (p) Ltd. v. lTO13 of which one of us (Justice G.s. Kurkarni) was a member, wherein the court categoricary observed that the Revenue having not "accepted" the judgment of the High Court would not mean that till the same is set aside in a manner known to law, it would loose tts binding force. Refening to the decision of the Supreme Court in Union of lndia vs. Kamlakshi Finance Corporation Ltd.14, the court observed that the approach of the officiars of Revenue of treating decisions being^,,not acceptable,, was criticized by the Supreme Court. ln such decision, following are the relevant observatrons made by the Supreme Court.

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]l^{gql:,r.T0. raxmann.corn 422 (Bornbay)l} '' ilq781 | l3 ITR 58a 1g6,r6ur, 1,3,7zO241165 taxmann.com 5gI/300 Taxman 452 (Bornba1.)

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/ r'

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"6. Sri Reddy is^{perhapsright in sayingthat the} officers^{were not actuatedby any mala fides in} passing the^{impugnedordersTheyperhaps} genuinely felt^{that the claim of the assesseewas not} tenable^{and that, if it was accepted' theRevenue} would suffer.^{But whatSri Reddy overlooks is thatwe} are not^{concernedhere with the correctnessor} otherwise^{of their conclusionor of anyfactual} malafides^{but withthe factthat the officers' in reaching} in their^{conclusion, by-passedtwo appellateordersin} regard to^{the same issue which were placedbefore} them,^{oneof the Collector (Appeals) and the other of} the Tribunal.^{The High Courthas' in our view' rightly} criticized^{thls conduct of the Assistant Collectorsand} the harassment^{to the assessee caused by the failure} of these^{officers to give effect to the ordersof} authorities^{higherto themin the appellatehierarchylt} cannot^{be too vehemently emphasized that it is of} utmost^{importancethat, indisposingofthe} quasijudicial^{issues beforethem'revenueofficersare} bound^{by the decisionsof the appellateauthorities'} The order^{of the Appellte Collector is binding on the} Assistant^{Collectors working within his jurisdiction and} the order^{of the Tribunalis binding upon the Assistant} Collectors^{and the Appellate Collectors who function} under the^{jurisdictionof the TribunalThe principles of} judicial discipline^{requirethat the ordersof the higher} appellate authorities^{should be followedunreservedly} by the subordinate^{authoritiesThe mere fact that the} order of the^{appellateauthority is not"acceptable"to} the department -^{in itself an objectionable phrase -} and is the^{subject matterof an appeal can furnishno} ground for not^{following it unless its operationhas} been suspended^{by a competentcourt lf thishealthy}

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( r.'

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rule is not followed, the result will only be undue harassment to assesses and chaos in administration of tax laws.

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We have dealt with this because it has been ,rrr:;::t;tTl"":::l Additional Solicitor General that the observations made by the High Court, have been harsh on the officers It is clear that the observations of the High Court, seemingly vehement, and apparenfly unpalatable to the Revenue, are only intended to curb a tendency in revenue matters which, if allowed to become widespread, could result in considerable harassment to the assesses_public without any benefit to the Revenue. We would like to say that the department should take these observations in the proper spirit_ The observations of the High Court should be kept in mind in futu shourd be paid by the r.jr.,;,iliff;:[T::Til: appellate authorities to the requrrements of judicial discipline and the need for giving effect to the orders of the higher appellate authorities which are binding on them."

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I 5 ' what is won)i ing this Bench more is the fact that an endeavour is being made whole heartedly to ensure not to generate further litigation on issues which have been laid to rest by a large number of High Courts all of whom have taken a consistent stand that the action of the Income Tax Department being violative of the

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F'inance^{Act,2O20 and Finance Act'2021' Now' in orderto protect} the interest^{of the Revenue as also that of the assessee'it would be} trite at^{this juncture, if we dispose of the writ petition with an} observation/direction^{that the disposal oftheinstant writ petition in} terms of^{the judgmentrenderedby this High Court in the case of} Kankanala^{RavindraRetldy (l supra) shall howeverbe subject to} the outcome^{of the SLPs which were filed by the IncomeTax} Deparlment^{and which is pending consideration before the l{on'ble} Supreme^Court.

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In^{the given iacts and circumstances' this Bench is of the} considered^{opinion that unless and until we do not timely dispose} of matters^{which aresquarely covered by the decision of this Cou(} and which^{stands fortihedby the decisions ol the variousother} High Courts^{on the very same issue' the pendency of this High} Court^{would further be burdenedwhichotherwisecan be decided} ancl disposed^{of as a covered matter'}

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11 . So far as^{the interestof the Revenue is concemed' we are of} the considered^{opinion that the interestof the Revenuehasalready} been considered^{and protected,as has been observedin paragraphs} lt

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36,37 and 3g of the order which, for ready reference, is reproduced

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hereunder.:

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For all the aforesaid reasons, the impugned notices issued and the proceedings drawn by the respondent_ Department is neither tenable, nor sustainable. The notices so issued and per se iresar, deserves ," ;:H":,.:".:"tffiil1: aside/quashed. As a conse all the impugned orders getting quashed, ,n" "o'un""' by th e re s po n de ". o. o" nr.li "r"Jo..ii,ltl? :T: ff ::: issued under Section 147 quashed and it is o,o","o,"1llal;1;T[ ,:j::, l: are quashing the consequential order is on the principles that when the initiation of the proceedings itself was procedurally wrong, the subsequent orders also gets nullified automatically

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The preliminary objection raised by the petitioner is sustained and all thi-.se writ petitions stands allowed on this very jurisdictional issue. Since the impugned notices and orders are gefting quashed on the point of jurisdiction, we are not inclined to proceed further and decide the other issues raised by the petitioner which stands reserved to be raised and contended in an appropriate proceedings.

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38 Since the Hon,ble Supreme Court had, in the case of Ashish Agarwal, supra, as a one-time measure exercising the powers under A(icle 142 of the Constitution of lndia, permitted the Revenue to proceed under the substituted provisions, and this Court allowing the petitions only on the procedural flaw, the right r /

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conferred on^{the Revenuewould remainreserved to} proceed further if they^{so want from the stage of the} Court in the^{caseof Ashish} order of the^SuPreme Agarwal,^suPra.

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We^{would only further like to make obserwationsthat since} we are inclined^{to dispose of the instantwrit petition'consciousof} thefactthattheearlierorderofthisHighCourtinthecaseof Kontrkala^{Ravindra Reddy (lsupra) is subjectedto challenge} belore^{the Hon'ble SupremeCourt in SLP No'3574 of 2024'} preferred^{by the lncome Tax Department' we makeit clear that} allowing^{of the instantwrit petition is subjectto outcomeof the} aforesaid^{SLPpreferred by the Revenue against the decisionof this} HighCourtinthecaseofKanakalaRavindraRedtly(|slpra). I'his, in^{otherwords, wouldmean that either of the parties'if they} so want,^{may movean appropriate petitionseekingrevival of this} writ petition^{in the lightof the decisionof the Hon'ble Supreme} Court in^{the pending SLP on the very same issue'}

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Accordingly,^{the instant writ petitionstands allowed in} lavouroftheassesseesofarastheissueofjurisdictionis concemed.^{As a consequence,the impugnednoticeunder} challenge under^{Sections 148-A and 148 standsset aside/quashed'}

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f.:t

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The consequential orders, if any, also stand set aside/quashed in similar terms as have been passed by this High Court in the case of Kankanala Rtvintlra Redtly (l supra). There shall be no order as

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to costs.

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<br>I

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	standclosed. Consequently, miscellaneouspetitions pending,ifany,shall
	//TRUE COPY// SD/- L.VIJAYALAXMI ASSISTANT REGISTRAR it:.
To	SECTION OFFICER
1.	TheNational Faceless Assessment Centre, Income-tax Department,New Delhi,lndia.
SA T ", J. 4. 5. 6.	^{IP,l^":g:J:Lgli:"1,Ward1, rVlahabubnasar,Tetansana.} tneASSessmentUnit, lncome.Tax Department It/inistry"ofFinance, Government oflndia,New Delhi. OneCCtoSRI IV.NAGA DEEPAK,Advocate IOPUCI ONECCtOSRI. KSUDHAKARREDDiiS;..d;O"NIICOVETAX)AdVOCAIC toPUCl TwoCDCopies o