Allowed

Mrs. Shapuram Pushpa v. The Income Tax Officer

Telangana HC28 Apr 2025WP/34610/2024

Case brief

AI extract

What is this about?

The High Court allowed a writ petition challenging income tax notices and assessment orders issued by a jurisdictional Assessing Officer. The court held the proceedings violated Section 151A of the Income Tax Act as they were not faceless, relying on precedents and noting the department's failure to halt such actions despite prior rulings.

What did the court decide?

Impugned notice under Sections 148A and 148 stands set aside/quashed; consequential orders also set aside.

Mrs. Shapuram Pushpa Vs The Income Tax Officer — Writ and Judicial Review | Telangana HC (2025)

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t3447l

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lN rHE^{HIGH couRr FoR rHltlt"Tff,]5,:t}So*oAr HYDERABAD}

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MONDAY,^{THE TWENTYEIGHTHDAYOFAPRIL} TWO^{TH_OUSANDANDTWENTY FIVE}

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PRESENT

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THE HONOURABLE^{SRI JUSTICEP'SAM KOSHY}

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THE HONOURABLE^{SRIJUSTICE NARSING RAONANDIKONDA}

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WRIT PETITI^{ON NO:34610OF2024}

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Between:

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Mrs. House ShaPu^{wife,'fltitj3lift} ,Hl?.}llf^{:aBlJ:n":^'jtl]lB,T,:':i'u"n"ouo"?i'l'n;n"1"}

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,.PETITIONER

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AND

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rhe^{rncome rax orricer, ward 17-(1), ,Hvderai,Xh-t#ililfl"-LlY,?li,:} ' i; N;67Pt. kondapur, opp Botanical Garndes' H'VaeraU'aA^{- 500 084' Telangana}

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,ft :i?';If; i.*llll''ffil?3,]i,,Ei.iI}lE.k,}.i:"j,1i^j.}tf i.?il:.1!3?lli{' New Delhi

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rhe^Principal .chief^{Commissioner-of^ llcome ra-Orfl3i;",3i?:"rt[,3;;1} " i;i"^;;;;'Hvderabad PETITION ER lS Room ii:?;"*;;''i67^{a, nc Guaros' HYderabad}

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...RESPONDENTS

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Petition^{under Article 226 of lhe Constitutionof lndia praying that in the} circumstances^{statedin the affidavit filedtherewith'the High Court may be} pleased to issue^{a Writ of Mandamusor any other appropriate Writ' Orderor} Direction.^{declaringthata )the order passed by the 1st Respondent u/s 147 Ow} Sec. 144^{of the lncome Tax Act' 196'l' datedOB03'2024' bearing DIN and Notice} No. .rBA/AST/^{st147t2023_z4t1o62z4so76(1), for the Assessmentyear 2016 - 17} and b.)the^{orders passedby the 2nd Respondent,revying penartiesu/s} 271F,271(1)(b)^{and 271('lXc) of the lncome Tax Act' 1961' dated 04'092024'} 24.0g'2024and24.og.2024,bearingDIN.ITBA/PNLtFl271Fl202425t10o8325205(1),^{lrBA/PNLtFt271(1)(b)t2024-25t106s048208(1)'and}

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lrBAlPNLlFt2Tl(1)(c)t2o2a-2s/1069067141(1), respectivery, for the Assessment Year 2016 -17'as arbitrary, illegal, bad in law, barred by time, void-ab-initio, violative of the principres of naturar justice, apart from being viorative of Articres 1 ' 19(1)(g) and 265 0f the constitution of India and Sec 14BA of the rncome Tax Act' 1961' and to consequenfly set aside the same in the interests of justice.

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lA NO: 1 oF 2024

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Petition under Section 151 cPc praying that in the circumstances stated in the affidavit fired in support of the petition, the High court may be preased to stay all further proceedings, including any recovery, pursuant to the notice uh. 148 of the Act' dated 24 03 2023, issued by the 1st Respondent, vide DrN and Notice. ,rBA/AST/S/148-112022- 23t1051267765(1), for the Assessment year 2016 _ 17, pending disposal of the above Writ petition.

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Counsel for the petitioner : SRI A.V.A.SIVA KARTIKEYA

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Counsel for the Respondents: Ms.J.SUNITHA, Jr.SG for lT DEpT

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The Court made the following: ORDER

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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.346100F 2024}

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9 8,^{(perHon'bte sri Justice Narsing RaoNarulikonda)}

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Heard Mr.^{A.V'A'Siva Kartikeya'leamed counsel for the} petitioner^{and Ms' J.Sunitha, learnedJunior Standing Counselfor} the Income^{Tax Departmentfor the respondents'Perused the} record.

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This is a writ^{petitionwherethe proceedingsare either} challenged^{to the notices whichwereissued under Section I48A} and 148^{of the Income Tax Ac[ 1961 (for short'the Act') or the} assessment^{orders those have been passedunder Section 147 of} the Act which^{have been assailed'}

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This writ^{petition is being taken up todayonly on one of the} grounds, that^{the noticesissuedunder Section 1484' of the Act} and the subsequent^{initiation ofproceedings under Section148 of} the Act by^{the jurisdictional AssessingOfficer, whereas in terms}

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of the amendrrynt^{that was brought to the IncomeTax Act by way} of Finance^{Acr, 2021 w'e'f', 01'04'2021 onwards'proceedings}

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under Section l4gA of rhe Act as also under Section l4g of the Act ought to have also been issued and proceeded in a faceless manner.

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The contention of the petitioner is that the issue of proceedings being in violation of the Financ e Act, 2021 i.e., the impugned notices under Section 14gA and Section l4g ofthe 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 ailowed and the proceedings initiated under Section r4gA as arso under section 148 of the Act were held to be bad with consequential reliefs on the ground of it being in vioration of the provisions of Section 1 5 r A of the Act read wirh Norification lg/2022 dated2g.O3.2022. The said judgment passed by this Court has also been subsequently followed in a large number of writ petitions which were alrowed on similar terms

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

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Down^{the line' we find that the sameissue has also been} decided^{against the Revenue by variousHighCourts i'e"} by the^{BombayHigh Court in the case of HEXAWARE} TECHNOLOGIES^{LTD., VS. ASSISTANTCOMMISSIONER} OF^{INCOMETAX & OTHERS2' GauhatiHigh Court in the case} of RAM^{NARAYAN SAH vs' UNION OF INDIA3'Punjaband} HaryanaHigh^{Court in the case of JATINDER SINGH BANGU} vs. UNION^{OF INDIA4'and TelanganaHigh Courtin the case of} SRI^{VENKATARAMANAREDDY PATLOOI,AVS. DEPUTY} COMMISSIONER^{OF INCOME TAX5 wherethe issuewas in} respect^{of intemational taxation' Bombay High Court in the case of} ABTIIN^{ANILKUMARSIIAIIVS. INCOME TAX OFFICER"} INTERNATIONAL^{TAXATION6 which is again on international} hxation^{and central circre,High court of Himacharpradeshin the} case of^{GOVINDSINGII vs' INCOME TAX OFFICERT'} Gujarat^{High Court inthe case ofMANSUKHBHAI}

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, lzoz+1464 lrR 430 (Bom)

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, i,zoz+i 156 taxmann.com 478^(Gauhati)l 'iirt;)^{165 taxmann'com115 (Punjab &Haryana)l} 'f)OZql'^{167 taxmann.com 411 (Telangana)l} -

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"izozq)^{166 taxmann.com 679 (Bombay)l} 'i;o;ii -^{ii1,r*.*tom I l3 (HimachalPradesh)l} 4-\

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DAHYABHAI RADADIYA vs. INCOME TAx OFFICE& WARD 3(3X5)8, Jharkand High Court in the case of SHyAM SUNDAR SAW vs. UNION OF INDIAe, Rajasthan High Court in the case of SHARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER and batch of writ petitionsr0 which stood decided oo 19.03.2024. Similar views have also been taken by the Division Bench of Calcutta High Court in the case of GIRDHAR GOPAL DALMIA vs. UNION OF TNDIA & ORS (M.A.T I 690 ot 2023.decided on 25.09.2024.

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Even though the same issue having been decided by a large number of High Courts, we are still confionted with large filing of identical matters on daily basis ranging between 5 to 10 writ pehttons. That upon the instructions being sought fiom 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 Court in the case of Kqnakala Ravindra Reddy

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'2024^sCConline Guj 40tZ '2025 SCC Online lhar287 'o 72023^{: RJ-JD} :4984-DBl

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(1 supra)^{has been subjectedto challenge in a SpecialLeave} Petition^{i.e., SLP No'3574 of 2024 before the Hon'ble Supreme} Court^{and the Hon'bleSupremeCourt is seized of the matter'} In addition,^{there are about1200 SLPs also filedarising out ofthe} same^{issue being decided by various High Courts'}

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To a^{query being put to the learned counselfor the Revenue'} they^{have categorically accepted the fact that there is no interim} order^{granted by the Hon'bleSupremeCourt in any of these} matters^{pendingbefbre it'Meanwhile' fresh writ petitionsof} identical^{nature are being piled up beforethis Benchon daily basis} and^{the pendency is getting increasedon matterwhich otherwise} hasalreadybeendealtanddecidedbythisveryHighCourtitself.

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On the^{one hand, even though the order of this Courtthat} was^{passed as earlyas on 14'09'2023and more 16 monthshave} lapsed, till^{date, we do not find any remedial steps havingbeen} taken by^{the lncome Tax Departmentto take appropriatesteps to} either^{hold back issuance of notice under Sectionl48A and under} Section^{148 of the Act by the jurisdictionalAssessingOfficer'} rather the^{authorities concemed in the teeth of series of decisions}

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by all the major High Courts in India are continuously still initiating proceedings under Section l48A of the Act and also initiating proceedings under Section 14g of the Act in contravention to the amendments brought into the Income Tax Act pursuant to the Finance Act,2020as also the Finance Act202l.

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9' upon a query being put as to why can,t this wnt petition be disposed of in the teeth of the decision rendered by this Court in the case of Kanakalu Rwindm Reddy (l supra), leamed Standing Counsel for the Income Tax Department contends that those would unnecessarily burden the Income Tax Department where they would be required to fire equar number of SLps before the Hon'ble Supreme Court and it would be further burdening the exchequer of the Union oflndia. 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 writ petition is kept pending till the ftnalization of the SLps pending before the Hon,ble Supreme Court and the fact that the petitioner is already enjoying the benefit ofinterim protection. 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

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appropriate^{stepsin ensuring that proceedingsunder Section148A} ofthe^{Act as also the assessment orders under Section148 ofthe} Act are^{kept in a hotd in the light ofthe decisions dedcidedby the} various^{HighCourts,it was submitted by the learnedStanding} Counsel^{that the said steps can only be taken at the level of CBDT} as any^{suchsteps wouldhave to be taken Pan India and cannot be} limited^{to anyof these jurisdictionalHigh Courts'}

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As^{a result of which, what we are facing is steep increase of} litigation^{day in and day out even though variousorders have been} passed by^{this High Courtallowing writ petitionson the verysame} issue.^{The Income 'I ax authoritiesconcemed are still even now in} 2025 also^{initiatingproceedingsin contravention to the provisions} of Section^{15 1A of the Act and as a result by now' more than 600} toT00petitionshavebeenalready.gotpiledupbeforethisHigh Court on^{an issue whichotherwisestandssquarely coveredby the} judgment of this^{Court in the case of Kanukala RavindraRedd'y} (1 supra).^{What is also surprising is the fact that though while} allowing^{the writ petitions in the case of Kanakala Ravindra} Reddy (l^{supra), the DivisionBenchwhilereserving the right of} the Revenue,^{has also protected the interestof the petitioners}

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tnsofar as the liberty which was granted to the Revenue for initiating fresh proceedings strictry in accordance with the amended provisions of the Act, as amended by the Financ e Act, 2020 and, the Finance Act, 2021. The petitioner assessee would be entitled to challenge or raise the other legal objections irthe 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 mahy other High Courts already held to be bad.

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I l. It appears that because ofthe aforesaid 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 advantage of the same by protracting these proceedings which would enable them 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 and finally at a later stage if the Hon,ble Supreme Court confirms the decision taken by this High Court as also by the other High Courts in which the SLps are still pending, nthe Income Tax

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f the^{libertY that is otherwtse} Department^{wouldget the advantage o} Revenue^{for initiation of fresh} protected^{in favour of the} f these^{matters at a much laterstage} proceedings^{from the disPosalo} and^{beneficial to the Revenue and} which^{would be advantageous} would^{be equatly disadvantageous and detriinentalso far as interest} of the^{assesses are concemed' As a consequence'the Income Tax} Department^{gets an extendedperiod of time for initiation of fresh} proceedings'

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12.^{The alarmingtrendof docketexplosionin this Court' despite} Kanakala^{RavindraRefuty (l supra)' is a} the clear Precedent^{set tn l} matter of^{grave concern' The Income Tax Department's persistent} initiation^{of fresh proceedings,disregarding the establishedjudicial} pronouncements,^{has led to an unprecedentedsurge in litigation} with over^{600-700petitions piling up on the same issue'This} deliberate^{approach not only undermines the principle ofjudicial} precedent^{but also strains the judicialresourcesunnecessarily' The} Department's^{strategyof awaiting the Supreme Court's decision on} pending SLPs^{while continuing to initiate fresh proceedings} appears to^{be a calculatedmove to buy time and circumvent} limitation^{perionds, rather than adhering to the establishedlegal}

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posltion. Such conduct raises serious questions about the administrative efficiency and the respect for judicial pronouncements, particularly when this Court has alreadyprovided 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 that proceedings 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 already seized ofor, at Ieast the Income Tax Department should have found 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 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 Tax Department, has not been able to give a convincing reply, except for the fact that such a f,ecision if at all

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has to^{be taken,has to be taken for the whole of India' and which} otherwise^{hasto be by way of a policy decision and that too at the} level of^{Central Board of DirectTaxes' Though the leamed} Standing^{Counselfor the IncomeTax Departmentcontended that} the Delhi^{High Courtdismisseda writ petitionof similar nature' on} the one^{hand whenthe High Court is stmggling to reduce its} pendency,^{such noticeswhichare under challenge in this writ} petition are^{forcing the assesseeto knock the doors of this High} Court^{resultingin filing of hundredsof new writ petitions which in} the long^{run not only affects the disposal of the writ petitionsbut} also^{consumessubstantial time of the Bench in hearing these} matters^{again and againon daily basis' Admittedly' in spite of the} matter^{before the Hon'ble Supreme Court having been taken on} many occasions,^{the Hon'ble Supreme Court which is seizedof the} matter^{has been reluctantin granting any interim protection to the} Income^{Tax Department'Yet, the authorities concemedat the} State^{level are not ready to accept the verdictpassed by a maj ority} of HiC{r^{Courts of differentStateson the same issue; and to make} things^{lfurther worse, the Income TaxDepartmentis showing} audacity^{by issuing notices continuouslyunder Sections148-4and}

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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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In the case of BANK OF INDIA vs. ASSISTANT COMMISSIONER, INCOME TAXil, on an issue whether it was justifiable on the part of the Income Tax Department in not following an order passed by the adjudicating authority only on the ground that the appeals are pending, the Division Bench of the High Court of Bombay held at paragraph No.25 as under, viz., :

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"25' Mr. paridwara has righry drawn out attention to the decision of this Court in Commissioner of Income Tax vs. Smt. Godavaridevi Sarafr2 as also the recent decision of the coordinate Bench of this Cr t^ill or wh i ch o n e or us,r r.,,"'"' I l r:il:: :j:i::t; ;r'":; 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 its binding force. Referring to the decision of the Supreme Court in Union of lndia vs. Kamlakshi Finance Corporation Ltd.r4, the Cou( observed that the approach of the officials of Revenue of treating decisions being *not acceptable,, was criticized by the Supreme Court. ln such decision, following are the relevant observations made by the Supreme Court.

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',1, l}ol;t,r.t3 .r=rmann. com 422 (B ombay) ) '- t Ie78l I I3 ITR 589 (Bombay) " 12024) I65 taxmann.com 5gl/300 Taxman 452 (Bombay)

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'o Tl}gZltaxmann.com 16/ 55 ELT433 (SC)

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I t

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"6. Sri Reddy is perhaps right in saying that the officers were not actuated by any mala fides in passing the impugned orders. They perhaps genuinely felt that the claim of the assessee was not tenable and thal, if it was accepted, the Revenue would suffer- But what Sri Reddy overlooks is that we are not concerned here with the^. correctness or otherwise of their conclusion or of any factual malafides but with the fact that the officers, in reaching in their conclusion, by-passed two appellate orders in regard to the same issue which were placed before them, one of the Collector (Appeats) and the other of the Tribunal. The High Court has, in our view, righfly criticized this condupt of the Assistant Collectors and the harassment to the assessee caused by the failure of these officers to give effect to the orders of authorities higher to them in the appellate hierarchy. lt cannot be too vehemently emphasized that it is of utmost importance that, in disposing of the quasUudicial issues before them, revenue officers are bound by the decisions of the appellate authorities. The order of the Appellte Collector is binding on the Assistant Collectors working within his jurisdiction and the order of the Tribunal is binding upon the Assistant Collectors and the Appellate Collectors who function under the^jurisdiction of the Tribunal. The principles of judicial discipline require that the orders of the higher appellate authorities should be followed unreservedly by the subordinate authorities. The mere fact that the order of the appellate authority is not "acceptable" to the department - in itself an objectionable phrase - and is the subject matter of an appeal can furnish no ground for not following it unless its operation has been suspended by a competent court. If this healthy

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1.4

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rule is net followed, the result will only be undue harassment to assesses and chaos in administration of tax laws.

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12 We have dealt with this aspect at some length, because it has been suggested by the learned Additional Solicitor General that the observations made by the High Court, have been harsh on the officers. lt 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 widespre?d, 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 future and the utmost regard should be paid by the adjudicating authorities and the appellate authorities to the requirements 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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15 what is worrying 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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Finance^{Act, 2020and FinanceAct'2021' Now' in order to protect} the interest^{of the Revenueas alsothat of the assessee'it would be} trite^{at this juncture' if we dispose of the writ petitionwithan} observation/direction^{that the disposal of the instant writ petition in} terms^{of the judgmentrendered by this High Court in the case of} Kankanara^{RavindraReddy (r supra)shafl however be subject to} the outcome^{of the SLPswhich were filed by the IncomeTax} Department^{and which is pending considerationbefore the Hon'ble} Supreme^Court'

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16.^{In the given facts and circumstances' this Bench is of the} considered^{opinion thatunless and untit we do not timely dispose} of matters^{which are squarely covered by the decisionof this Court} and^{whichstands fortihedby the decisionsof the various other} High Courts^{on the very same issue'the pendency of this High} Court^{would further be burdenedwhich otherwisecan be decided} and disposed^{of as a covered matter'}

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So^{far as the interestof the Revenue is concemed' we are of} the considered^{opinion that the interestof the Revenuehas already} been considered^{and protected,as has beenobserved in paragraphs}

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

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hereunder:

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For all the aforesaid n i s s ue d a n d,.,u p ro"u"i ins"r' :::;iTJTJi::il:::? Department is neither tenable' nor sustainabre. The notices so issued and Procedure adopted being per se iflegar, deserves ,othe be and are accordingly set aside/quashed. As a cons all the impugned orders getting quashed, ,n" ,uou"ntu' by the responde".r"*-r::ltT,:::::,lT: :ffi:: issued under Section 147 quashed and ir is *0",."0 .;:o"lffiT ,Jj::, ;j are quashing the consequential order is on the principtes that when the. initiation of the proceedings itself was procedurally wrong, the sub nulified automaticafly.^{'sequent ordersalso gets}

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The preliminary objection raised by the petitioner is sustained and all these writ petitions stands allowed on this very jurisdictional issue. Since the impugned notices and orders are getting 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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Since the Hon,ble Supreme Court had, in the case of Ashish Agarwal, supra, as a one-time measure exerCising the powers under Articte 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}

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conferred^{on theRevenuewould remain reservedto} proceed further^{if they so wantfrom the stage of the} order of^{the SupremeCourt in the case ofAshish} Agarwal,^suPra.

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18.^{We would only further like to make observationsthat since} we are^{inclined to dispose of the instant writ petition'consciousof} the fact^{that the earlier order of this High Court in the case of} KanakalaRavindraReddy(lsupra)issubjectedtochallenge before the^{Hon'ble Supreme Court in SLP No'3574 of 2024'} preferred^{by the lncome Tax Department' we make it clear that} allowing^{of the instant writ petition is subj ect to outcomeof the} aforesaid^{SLP preferredby the Revenue againstthe decisionofthis} High Court^{in the case of Kanakala Ravindra Reddy (lsupra)'} This, in^{other words,would mean that either of the parties'if they} so want,^{may move an appropriatepetitionseekingrevival of this} writ^{petition in the light of the decisionof the Hon'bleSupreme} Court in the^{pending SLP on the very sameissue'}

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19 Accordingly,^{the instant writ petitionstandsallowed in} favour of the^{assessee so far as the issue of jurisdiction is} concemed.^{As a consequence,the impugnednotice under} rphallenge^{under Sections 148-4 and148 standsset aside/quashed'}

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

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to costs.

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Consequently, miscellaneous petitions pending, if any, shall

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stand closed.

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SD/-M. OSMAN ALI BAIG ISTANT REGISTRAR //TRUE COPYII

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SECTION OFFICER

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1 lgnature Towers, rilin gampally, R.R. District,

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iiJ:[8:;fl ltfr ;{f i"",,^{j_,#Jrk,Hils3sls3}

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1. The Assessment Unit lncome Tax D-epartment, National a Assessment .rawarrirrir r.rerrru

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S,",,il:fi9r6,j,,n,*.o,^{ruo aoi -z"iJFi;;';,,E'H:,p,}

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3 The Principat Chief a"rll+:g,,o1r9r_oI tncome Tax, Andhra pradesh and Telanoana Hvderabact pETtTtON ER iS R;;;i?;'. s22, gthFtoor, B Btock, LTTowers. 1b23 AC Guards, HGrrOiO""""'"

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