Allowed

Smt. Kavitha Lakkapatri v. Assessment Unit

Telangana HC11 Jul 2025WP/19952/2025

Case brief

AI extract

What is this about?

Writ petition challenging reassessment notices under Sections 148A and 148 issued non-facelessly contrary to Finance Act amendments. Following the Telangana High Court's Kanakala Ravindra Reddy decision and multiple other High Courts, the bench quashed the notices, subject to outcome of pending Supreme Court SLPs.

What did the court decide?

Impugned notices under Sections 148A and 148 for AY 2018-19 set aside/quashed along with consequential orders, if any; subject to outcome of pending SLP; no costs.

Smt. Kavitha Lakkapatri Vs Assessment Unit — Income Tax | Telangana HC (2025)

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HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction)

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FRIDAY,THE ELEVENTH DAY OF JULY TWO THOUSAND AND TWENTY FIVE

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PRESENT

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THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE NARSING RAO NANDIKONDA

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WRIT PETITION NO : 19952 OF 2025

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Between:

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Smt Kavitla Lakkapatri, D/o. ganga Ram Abbala Ram Abbala, Aged about 54 years, Occupation. House Wife, plot No.12A, Jupiter Colony, iirumagiri, Secunderabad - 500015.

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AND

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...PETITIONER

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'1. ssessment 9-nit, National Faceless Assessment Centre. lncome Tax ?epa,rtmg{'!.^{Ministry..of Fihance, Room No. 4O1 . 2nd Ftoor, -E_Ra;p;} Jawaharlal Nehru Stadium, Delhi - 110 003.

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1. The. lncome Tax Officel, Ward-10(1), l.T. Towers, A.C. Guards, Masabtank, Hyderabad - 500004.

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...RESPONDENTS

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Petition under Articre 226 o'f the constitution of rndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to pass an order or direction, especially one in the nature of wRlr oF MANDAMUS holding, that the order passed by 2nd Respondent u s.148A(d) of the Act. dt.2110812024 with DtN and Notice No. |rBA/ASTtFt14BAt2o242511067826046(1) and the notice dated 21t08t2024 issued under section 148 of the Act with DIN and Notice No.|rBA/AST/St14B_1t2o24-25t1067826276(1) for the assessment year 2O1B-19, as being illegal, arbitrary and passed in gross violation of principles of natural justice without apptication of mind, and consequently set aside the same

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IA NO: 10F²⁰²⁵

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PetitionunderSectionl5lCPcprayingthatinthecircumstancesstated in the affidavit^{filed in support of the petition, the High court may be pleasedto} suspend the^{operation of the notice issuedby the 2nd Respondentu/s'148 of the} Act, dl.21tOBt2O24^{for the assessment year 2018-19with DIN and Notice No'} ITBA/AST/S/148_1t2o24.25t1o67s26276(1)andallconsequentialproceedings thereto

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Counsel^{for the Petitioner:SRl. A' V' RAGHU RAM}

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Counsel for^{the Respondents: Ms' BOKARO SAPNA REDDY} (sENlOR SC lNcoME^TAX)

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The Court^{made the following:ORDER}

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,.?.x

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_ -

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HONOURABLE SRI IUSTICE P.SAM^KOSHY AND

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HON'BLE SRI JUSTICE NARSING^{RAO NANDIKONDA}

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WRIT PETrrIoN NO.199s2^{0F 202s}

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ORDER (per Hon'ble Sri lustice P.Sam Koshy)

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Heard Mr. A.V.Raghu Ram,^{Iearned counselfor the petitioner} anct Ms.B.Sapna Reddy,^{learned Senior Standing Counselfor the} Income Tax Department appearing^{for the respondent Nos.1 and 2} Perused the rccord.

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This is a writ petition where^{the proceedings are either} challenged to the notices^{whichwereissued underSection 148,4 and} 148 of the Income Tax Act,^{1961 (for short'theAct') or the assessment} orclers those have been^{passed underSection1'47 of the Act which} have been assailed

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This writ petition is being^{taken up today only on one of the} grounds, that the notices^{issuedunder Section 148Aof the Act and the} subsequent initiation of proceedings^{under Section 148 of the Actby} tl-re jurisdictional Assessing Officer,^{whereasinterms ofthe} amenclment that was brought to^{the Income Tax Act by way of Finance}

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Act,2021 w.e.f .,01,.04.2021 onwards,^{proceedingsunder Section 148,{} of the Act as also under Section^{148 of the Act oughtto have also been}

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issued and proceeded in a faceless manner.

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HONOURABLE^{SRI JUSTICE P'SAM KOSHY} AND HON,BLE^SRI JUSTICE^{NARSINGRAO NANDIKONDA}

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WRIT PETITIO^{N NO.19952oF 2025}

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oRDER (per Hon'btc^Sri ltrsttce^{P'SnlrrKoshy)}

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Heard Mr.^{A'V Raghu Ram' Iearned counsel for the petitioner} and Ms.B.Sapna^{Recldy' learned Senior Standing Counselfor the} Income^{Tax Departmentaprpearing for the respondentNos'1 and 2'} Perused^{the record}

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This is a^writ Petition where the Proceedings^{are either} challenged^{to the rroticc's whidr were issuedunderSection 148A and} 148 of the^{Income Tax ;\ct, 1961 (for short'theAct') or the assessment} orders^{those have been passecl under Section 147 of the Act which} have been^assailecl

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This wrii^{petitionis being taken up today only on one of the} grounds,^{that the notices issued under Section 148Aof the Act and the} subsequent^{initiation of proceeciings under Section 148 of the Act by} the^{jurisdictionatAssessingOfficer' whereasinterms ofthe} amendment^{that was broughtto the IncomeTax Act by way of Finance} Act, 2027^{w.e.f ., 01 04 2021onwards'proceedingsunderSection 148A} of the Act^{as also underSection148 of the Act oughtto have alsobeen}

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issued ancl^{proceec{edin a faceless manner'}

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4' The contention of the petitioner is that the issue of proceedings \ being in violation of the Financ e Act, 2027 i.e., the impugned notices under section 1484 and section 14g of the Act not beir-rg issued in a facelcss mallner, have already been dealt with and decided by this Court in the case of KANKANALA RAVINDRA REDDy vs. INCOME-TAX OFFICER1 decided on 74.09.2023 whereby a batch of writ petitions were allowed and the proceedings initiate<i under section 1484 as also under section 14g of the Act were helcr to be bad with consequcntial reliefs on the ground of it being in violation of the provisions of section 1514 of the Act read with Notification 7g/2022 dated 29.03.20 22. Therurd -jrdr-"rlt passed by this Court has also been subsequently followed in a large number of writ petitions which were allowed on similar terms.

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Down the line, we find that the same issue has also been decicled against the Revenue by various High Courts i.e., by the Bombay High Court in the case of HEXAWARE TECHNOLOGIES LTD., vs. ASSISTANT COMMISSIONER OF INCOME TAX & OTHERS2, Gauhati High Court in the case of RAM NARAYAN SAH vs. UNION OF INDIA3, Punjab and Haryana High Court in the case of |ATINDER

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' [(2023) 156 raxrnann.corn 178 (Telangana)]

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'lzoz+1464 ITR 430 (Born)

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' l(2024) 156 taxmann.corn 478 (Gauhati)l

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SINGH BANGU vs. UNION OF INDIAI, and Telangana High Court in the case of SRI VENKATARAMANA REDDY PATLOOLA vs. DEPUTY COMMISSIONER OF INCOME TAX5 where the issue was in respect of international taxation, Bombay High Court in the case of ABHIN ANILKUMAR SHAH VS. INCOME TAX OFFICER, INTERNATIONAL TAXATION0 lvhich is again on international taxation and central circle, High Court of Himachal Pradesh in the case of GOVIND SINGH vs. INCOME TAX OFFICERT, Gujarat High Court in the case of MANSUKHBHAI DAHYABHAI RADADIYA vs.

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INCOME TAX OFFICER, WARD 3(3)(5)8, Jharkand High Court in the case of SHYAM SUNDAR SAW vs. UNION OF INDIAe, Rajasthan High Court in the case of SHARDA DEVI CHHAIER vs. INCOME

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TAX OFFICER & ANOTHER ancl batch of writ petitionslo which stood decided on 79.03.2024. Similar views have also been taken by the Division Bench of Calcutta l{igh Court in.the case of GIRDHAR GOPAL DALMIA vs. UNION OF INDIA & ORS (M.A.T L690 of 2023), decided on 25.09.2024

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" l(2024)^{165 taxrnann.corn I l5 (Punjab} & Haryana)l '12024)^{I 67 taxmann.corn4l I (Telangana)l}

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" 12024) 166 taxrnann.com 6T9 (Bornbay)l '12024)¹⁶⁵ taxmann.com I l3^(Himaclial Pradesh)l 82024 SCC Online Guj 4012 '2025 SCC Online Jhar287 o ' 72023^{: RJ- JD: 49 84-DB} l

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Everr 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 tl-re 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 Hexau.tare Technologies Ltd., (2 supra) as also the one wlricl-r has been decided by this Court in the case of Kanakala Raaindra Reddy (l supra) has been subjected to challenge in a Special Leave Petition i.e., SLP No.3574 of 2024 before the Hon'ble Supreme Court ancl the Hon'ble Supreme Court is seized of the matter ln addition, there are about 1200 SLPs also filed arising out of the same issue being clecided by various High Courts.

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To a query being put to the learned counsel for the Revenue, they have categorically accepted the fact that there is no interim order granted by the l{on'ble Supreme Court in any of these matters pending before it. Meanwhile, fresh writ petitions'of identical nature are being piled up before this Bench on daily basis and the penclency is getting increased on matter which otherwise has already been dealt and decided by this very High Court itself.

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On the one hand, even though the order of this Court that was passed as early as on 74.09.2023 and more 16 months have lapsed, till

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i'1*{' r.'. .,:

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date, we do not find any remedial steps having been taken by the Income Tax Department to take appropriate steps to either hold back issuance of notice under Section 1484 and under Section 148 of the Act by the jurisdictional Assessing Officcr, rather the authorities concerned in the teeth of series of clecisions by all the rnajor High Courts in lndia are continuously still initiatir-rg proceedings under Section 14BA of the Act and also initiating proceedings under Section 148 of the Act in contravention to the amendments brought into the Income Tax Act pursuant to the Finance Act,2020 as also the Finance Act 2021

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Upon a query being put as to why can't this writ petition be disposed of in the teeth of the decision renc'lcred by this Court in the case of Kanakaln Raoindra Reddy (7 supra), Iearncd Standing Counsel for the Income Tax Department contencls that those would unnecessarily burden the Income Tax Department where they would be required to file equal number of SLPs bcfore the Hon'ble Supreme Court and it would be further burdening the exchequer of the Union of India. It was also the contention of the learned Standing Counsel that no prejudice would be caused to the interest of the petitioners in case if this writ petition is kept pending till the finalization of the SLps pending before the Hon'ble Supreme Court and the fact that the petitioner 1S already enjoying the benefit of interim protection.

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Nonetheless, on the earlier query of this Court as to why the Income Tax Department have not come out with a mechanism to issue appropriate instructions or to take appropriate steps in ensuring that proceedings undcr Section 1484 of the Act as also the assessment orders under Section 148 of the Act are kept in a hold in the light of the decisions decided by the various I{igh Courts, it was submitted by the learned Standing Counsel that the said steps can only be taken at the level of CBDT as any such steps would have to be taken pan India and cannot be limitecl to any of these jurisdictional High Courts.

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As a result of which, what we are facing is steep increase of Iitigation day in and day out even though various orders have been passed by this High Court allowing writ petitions on the very same issue. The Income Tax authorities concerned are still even now in 2025 also initiating proceedings in contravention to the provisions of Section 151.4 of the Act arrd as a result by now more than 600 to 700 petitions have been already got piled up before this High Court on an issue which otherwise stancls squarely covered by the judgment of this Court in the case of Kanakala Raoindra Reddy (7 supra). What is also surprising is the fact that though while allowing the writ petitions in the case of Kanakala Raaindra Reddy (7 supra), the Division Bench while reserving the right of the Revenue, has also protected the interest of the

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petitioners insofar as the liberty which was granted to the Revenue for initiating fresh proceedings strictly in accordance with the amended provisions of the Act, as amended by the Finance Act,2020 and the Finance Act, 2021. The petitioner assessee would Lre entitled to challenge or raise the other legal objections if the Revenue initiates fresh proceedings. The Department has made no endeavour in availing the said liberty that was reserved for the Revenue. On the contrary, they have been still sticking on to the stand, which this High Court as well as many other High Courts already held to be bad

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It appears that becaus6 of the aforesaicl liberty that this High 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 aclvantage of the samc by protracting these proceedings which would enable tl-rem to meet the limitation that would otherwise come in the way. Likewise, if the writ petition is kept pending for a considerable long period of time anci finally at a later stage if the Hon'ble Supreme Court confirms the clecision taken by this High Court as also by the other High Courts in which the SLps are still pending, the Income Tax Department would get the advarrtage of the liberty that is otherwise protected in favour of the Revenue for initiation of fresh proceedings from the disposal of these matters at a much later

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stage which^{wouldbe advantageous and beneficialto the Revenue and} would be equally^{disadvantageous and detrimentalso far as interest of} the assesses^{are concerned. As a consequence,the Income Tax} Department^{gets an extendedperiod of time for initiation of fresh} .proceedings.

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L2. The^{alarmingtrenci of clocket explosionin this Court' despitethe} clear precedent^{set in Kanakala Raaindra Retldy (7 supra)' is a matter} of grave concern.^{The Income Tax Department's persistent initiation of} fresh proceedings,^{disregarding theestablishedjudicial} pronouncements,^{has led to an unprececlentedsurgein litigation with} over 600-700^{petitionspiting up on the sameissue'Thisdeliberate} approach^{not onlyundermines the principleof iudicial precedentbut} also strains^the iudicial^{resources unnecessarily'The Department's} strategy of^{awaiting the Supreme Court'sdecision on PendingSLPs} while continuing^{to initiatefresh proceedings appears to be a calculated} move to buy^{time and circumvent limitationperiods' rather than} adhering^{to the establishedlcgal position' Suchconductraises serious} questions about^{the administrativeeff iciency and the respect for judicial} pronouncements,^{particularlywhenthis Court has already provideda} both the^{Revenue's rightsand} balanced aPProach^bY Preservtng assesses interests.

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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 that procce,dings under Sections 148-,{ and 148 should not have been issuecl in a faceless manner/ at least till the Hon'ble Supreme Court decide the twelve hundrecl (1200) odd SLPs which it is already seizecl of or, at least the Income Tax Department should have found out some remec{ial steps to ensure that wherever the authorities intend to initiate proceedings under Sections 148-4 and 148, other than in a faceless manner, the proceedings should have been deferred without precipitating the mattcr further intimating the assessee that they shall initiate appropriate proceedings only after the SLP's are decided by the Hon'ble Supreme Court on the very same issue. This again, the Income'lax I)epartment, has not been able to give a convincing reply,.except for the fact that such a decision if at all has to be taken, has to be taken for thc ra,hole of India, and which otherwise has to be by way of a policy clecision and that too at the level of Central Board of Direct Taxes. 'fhough the learned standing Counsel for the Income Tax Department contenclcd that the Delhi High Court dismissed a writ petition of similar nature, on the one hand when the High Court is struggling to reduce its pender-rcy, such notices which are under challenge in this writ petition are forcing the assessee to knock the doors of this High Court resulting in fiiing of

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i I

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hundreds of^{new writ petitionswhichin the long run not onlyaffects} the disposal^{of the writ petitions but also consumessubstantial time of} the Bench in^{hearingthese matters again ancl again on daily basis'} Admittedly,^{in spite of the matter before the Hon'ble SupremeCourt} .having^{been taken on many occasions'the Hon'ble Supreme Court} which is seized^{of the matterhas been reluctant in grantingany interim} protection^{tothe IncomeTax DepartmentYet' the authorities} concerned^{at tl-reState levelare not ready to accept the verdict passed} by a majority^{of High Courts of different Stateson the same issue; and} to make things^{fur*rerworse, the [ncome l ax Departmentis showing} audacity by^{issuing noticescontinuously under Sections 148-Aand148} through the^{jurisdictionalAssessingOfficer whereasit ought to have} been onlY in^{the faceless manner'}

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L4. In the^{case ofBANK OF INDIA vs'ASSISTANT} COMMISSIONER,^{INCOME TAXtl' on an issue whether itwas} justifiable on the^{part of the IncomeTax Departmentin not followingan} order passed^{by the adjudicating authority only on the ground thatthe} appeals are^{pending,the Division Bench of the High Courtof Bombay} held at paragraph^{No.25as under, viz',:}

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" 11ZOZs)^{170 taxmann.corn 422(Bornbay)l}

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"25Mr. Paridwalla has rightly drawn out attention to the decision of this Court in Commissioner of Income Tax vs. Smt. Godavaridevi Saraft2 as also the recent decision o[ the co-ordinate Bench of this Court in Samp Furniture (P) Ltd. v. ITOtr of which one of us (Justice G.S. Kulkami) was a member, wherein the Court categorically observcd that thc Revenue having not "accepted" the judgment of thc High Court r,r,oulcl not mean that till the same is set aside in a manner known to [ar.v, it would loose its binding force. Referring to the decision of the Suprt,me Court in Union of India vs. Kamlakshi Finance Corporation Ltd.rr, the Court observed that the approach of the officials of Revenue of treating tlccisions bcing "not acceptable" was criticized by the Supreme Court. In such decision, following are the relevant observations made bv the Supreme Court.

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"6.Sri Recldy is perhqps right in saying that the officers wcre not achrated by any mala fides in passing the impuenecl orders. They perhaps genuinely felt that the claim of the assessee was not tenable and that, if it was acceptcd. the Revenue would suffer. But what Sri Reddy overlooks is that wc are not concerned hcre with the correchtess or otherwisr, of their conclusion or of any factual malafides but with thc fact that the officers, in reaching in their conclusion, bypassed two appellate orders in regard to the same issue which werc placed before them, one of the Coll(:ctor (Appeals) and the other of the Tribunal. The High Court has, in our view, rightly criticized this conduct of the Assistant Collectors and the harassment to the assessee caused by the failure of these officers to give cffect to the orders of authorities higher to them in the appellate hierarchv. lt cannot be too vehemently emphasized that it is of utmost importance tl.rat, in disposing of the quasijudicial issues

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'' 1toz81^{t l3 ITR 5ft9 (Bombay)}

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" 120241^{165 taxrnann.com 581/100 Taxrnan 452(Bornbay)}

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'o 119921^{tu*.ann.corrl6155ELT 433 (SC)}

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...j

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before them, revenue officers are^bout-tcl by thc^decisionsof thc appellate authorities.^Tl.re ordcr of^{the APpellteCollector} is binding on the Assistant Collectors^{workingwithinhis} jurisdiction and the order of the Tribunal is binding upon the Assistant Collectors and the Appcllate Collectors^who function under the^jurisdiction of thc Tribunal.^The principles of judicial disciptine require that^{thc orclelso[ the} higher appellate authorities should^bc follon'ed^unrcservedly by the subordinate authorities. The^mere fact that^{the order} of the appellate authority is not^"acceptable" to^thc department - in itself ah objectionable^phrase -^{and is the} subiect matter of an appeal can furnish no ground^{for not} following it unless its operation has been^{suspeuded b1' a} competent court. If this healthy rule is not followed,^thc result will only be tndue harassment^{to assessesancl cl.taosin} administration of tax laws.

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We have dealt with this aspect at some^{length,bccauseit} has been suggested by the learned Additional Solicitor General that the observations made bir thc Fligh Court,^have been harsh on the officers. It^is clcar^{tl.tattlre otrscrvationsof} the High Court, seemingly vchement,^{and apparerrtly} unpalatable to the Revenue, are or y intondcd to curb^a tenc{ency in revenue matters whicl.t, if allowed^{to become} widespread, could result in consic{erable^harassmeut to^the assesses-public without any benefit to the Reveuuc-^Wc would like to say that the departmcnt shoulcl^{take these} observaLions in the proper spirit. Thc^{observations of the} High Court should be kept in nincl in futurc^{and the utmost} regard should be paid by the adjudicating^{authorities and the} appellate authorities to the requirements^of iurlicial^disciplinc and the need for giving effect to the orders^{of tl.re higher} appellate authorities which are binding^{on them."}

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What is r.t orrying this Ber-rch more is the fact that an endeavour is

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being made whole heartedly to ensure not to generate further litigation on issues which have been raid 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 Financ e Act,2020 and Financc 4ct,2027. I.,-ow, in order to protect the interest of the Revenue as also that of the assessee, it would be hite at this juncture, if we dispose of thc writ petition with an observation/ direction that the disposal of the instant writ petition in terms of the judgment rendered by this High Court in the case of Kankatala Raoindra Reddy (7 supra) shall however be sub.iect to the outcomb of the slps which were filed by the Income Tax Department and which is pending consideration before the Hon'ble Supreme Court.

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In the given facts and circumstances, this Bench is of the consiclerecl opiniorr that unless and until we clo not timely clispose of matters which are squarely covered by the decision of this Court ancl which stands fortified by the decisions of the various other High Courts on the very same issue, the pendency of this High Court would further be burdened which otherwise can be decided and disposed of as a

covered matter

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17 . So far as^{the interestof the Revenue is concerned'we are of the} considered^{opinionthat the interest of the Revenue has alreadybeen} considered^{and protected, as has been observedin paragraphs36' 37} and 38 of^{the order which, for readv reference' is reproducecl} hereunder:

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"36. Forall^{the aforesaidreasons,the impugnednoticcsissrrcd} and the proceedings^{drawn by the respondent-Deptrrtmcntis} neither^{tenable, nor sustainable The noticesso issuedand the} procedure^{adoptedbeing per sz illegal'deserves to bc and are} accordingly^{set aside/quashedAs a consequence' all the} impugned^{ordersgetting quashed'the consequentialorrlers} passer-l by^{therespon<lent-DePartmentpursuantto thenoticcs} issuerl untler^{seition147 and 148 woulcl also get quasheclanrl it} is ordered^{accordinglyThc reasonwc are quashingthe} consequential^{order is on the principlesthatwhen the initration} of the^{proceedingsitself was procedurallywrong'tirc} subsequent^{orders alsogetsnullifiedautomatically'}

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The^{preliminaryobiection raised by thc petihonet ts} sustained^{and all these writ petitionsstands allowed on this} very jurisdictional^{issue' Since the impugnednoticesanclottlers} are getting^{quashed on the point oI iurisdichon'we aret.rot} inclined^{to proceed furtherand decidcthe other issur:sraisedby} the petitioner^{whichstandsreserved to be raisecland contended} in an apProPriate Proceedings'

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Since the^{Hon'bleSuPremeCourthad, in thc case} of Ashish^{Agarwal,suPra,asa one-timemeasurecxercisingthe} of the^{ConstitutionofIndia'} powers under^{Article 142} proceed^{under lhe substiiutccl} permitted^{the Revenueto} provisions,^{and this Courtallowingthc petitior-rsor-rlnor tl-re}

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proceclural flaw, the right conferret on the Revenue wourcJ remain reservecr to proceed further ,nu, so want from the stage of Lhe order of trre s,preme a, r , urt in the case of Ashish Agarwal, supra."

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We woulcl onl1, further Iike to make observations that since we \ arc. inclinecl to dispose of the instant writ petition, conscious of the fact that the earlier orcler of this High Court in the case of Kanakala Raaindra Rertrty (1 supra) is subjected to charenge before the Hon,bre Supreme Court in SLp No 3574 of 2[24,preferred by the Income Tax Departmer-rt' we make it clear that a,owing of the instant writ petition is subject to outcome of the aforesaid SLp preferred by dre Revenue against the decision of this High Court in the case of Kanakala Raoindra Redrry (7 supra) This, in other worcrs, wourd mean that either of the parties, if they so want, may move an appropriate petition seeking revivar of this writ petition in dre right of the clecision of the Hon'ble Supreme Court in the pending SLp on the very same issue.

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Accordingl_v, the instant Writ petition stands allowed in favour of the assessee so far as the issue of jurisdiction is concerned. As a consequence' the irnpugned notice uncrer challenge under sections 14g_ A and 14g stancis set a.side/quashed. The consequential orders, if any, - --. ,,rud r also stand set aside/quashecl in simila r t erms as have been passed by

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'.-(:_:-:x..- -

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!!--<-l

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this High Court in the case^{of Kankanala Raoitdra Rcilily (7 supra)}

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There shall be no order^{as to costs.}

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Consequently,^{miscellaneouspetitions pending, if any,shall}

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stand closed

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SD/- A.H.S.GOWRI SHAN KAR ASSISTANJ REGISTRAR //TRUE COPYII * _..^'- SECflON OFFICER

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To,

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l The Assessment- Unit, Nationar Faceress Assessment centre. rncome Tax ?up9,Ir."f !,fr4inistry^{of Finance, Room No.401 . 2ndf ioor, e_ijmpl -"} Jawaharlal Nehru Stadium, Delhi , 1 1^.10 003.

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