Allowed

Sri Rajaiah Enduri v. Assessment Unit

Telangana HC24 Apr 2025WP/4838/2025

Case brief

AI extract

What is this about?

Writ petition challenging notices under Sections 148A and 148 of the Income Tax Act not issued in a faceless manner, in violation of Section 151A provisions amended by Finance Act 2021. The court disposed it as covered by its earlier judgment in Kankanala Ravindra Reddy, quashing notices and consequential orders, subject to outcome of pending SLPs.

What did the court decide?

Notice under Sections 148-A and 148 and consequential orders set aside/quashed; no costs; misc petitions closed; subject to outcome of SLP No.3574 of 2024

Sri Rajaiah Enduri Vs Assessment Unit — Income Tax | Telangana HC (2025)

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13447 |

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

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THURSDAY,THE TWENTY FOURTH DAY OF APRIL TWO THOUSAND AND TWENW FIVE

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PRESFNT

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THE HONOURABLE SRI JUSTICE P.SAM KOSHY ANP THE HONOURABLE SRt JUSICq NARSING RAO NANDTKONDA

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WRIT PETITION NO:4838 OF 2o2s

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Between:

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Sri Rajaiah E@9r1, Slo. Sri E. Gattpiah, Aged about 76 years, Occupation Business, 4-122111A, Chandanagar, $eritingdmpalty, R.R. tiistrici - 500050.

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...PETITIONER

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AND

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Assessment Unit, National Faceldss Assessment Centre, lncome Tax Department,_ Ministry _of Finance, Room No. 401 , 2nd Floor, E-Ramp, Jawaharlal Nehru Stadium, Delhi - 1 10 003.

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The lncome Tax Officer Ward 8(1), Signature Towers, Opp. Botan jcal Gardens, Kondapur. Hderabad - 500084.

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Puniab National BanK PNB HO, Ground Floor, Wing Sector 10. Amberhai. South West Delhi-1 10075. Rep. by it$ Chairman and Manaqinq Drrector.

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lndustrial Development Bank of Indig (lDBl), 22"d Floor, Taiation Celt. lDgl Tower. Colaba S.O., Mumbai - 40Od05, Rep. by its Chairman and t,4anaging Director.

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...RESPONDENTS l

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Petitron under Article 226 of lhe Constitution of lndia praying that in the circumstances stated in the affidavit filpd therewith, the High Court may be pleased to pass an order or direction, eJpecialty one in the nature of WRIT OF MANDATVUS holding that. (i) the notice dated 06.04.2022 issued by 2nd Respondent under section 148 of the Act [with DIN and Notice No ITBA/AST/S 1148-112022-23/1042569058(1)l as being wrrhout iurisdiction, arbitrary, illegal, bad in law, void ab initio, apart from being violative of provisions of section 1 48 A and section 149 of the Act and also contrary to the circular issued by CBDT and provisions of section^'151 A of the Act, and consequenfly set aside the notice under section 148 dated 06.04.2022 and lhe assessment and penalty orders passed by 1st Respondent for asst. year 20i8-19 under section

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--E

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147 r.w.s^{l44 r w.s 1448, uls.270A} and u/s.271AAC(1) of the Act, dt.10.01.2024, 14.06.2024^{anc 18.06.2024,} respectively, (ii) the garnishee notices issued by the 2'd Respondent u/s.226(3) of the Act, dt.17.01.2025 to Respondents 3 and 4 as being illegal arrd unsustainable in law as the same are issued based on the assessment an(j penalty orders which are passed in violation of provisions of the Act'and violatio 1 of principles of natural lustice

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lA NO: 1 OF 2O',?-5

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Petition r- nder section 151 cpc praying that in the circumstances stated in the affidavit frled in support of the writ petition, the High court may be pleased to suspend the operation of garnishee notices dated 17.01.2025 issued by 2nd Respondent to the Respondenl Nos. 3 and 4 for collection of disputed taxes and penalty demands raised by 1st Respondent for the Ay.20.lB-19 lA NO: 2 OF 2025

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Petition under Section^'r 5r cpc praying that in the circumstances stated in the affidavit fi ed in support of the writ petition, the High court may be pleased to stay the colle:tion of drsputed taxes and penalty arising from the assessment and penalty orde rs passed by 1'r Respondent for the Ay 2019_1g

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Counsel for the Petitioner: Ms. K. PRABHABATI REp SRl. A. V. RAGHU RAM

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Counsel for the Respondent Nos. 1&2: Ms. J. SUNITHA

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(JUN|OR SC FOR TNCOME TAX)

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Counsel for the Respondent Nos. 3&4:--

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The Court made the following: ORDER

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THE HONOURABLE^{SRI JUSTICE P.SAM KOSIry} AI{D THE HONOURABLE^{SRI JUSTICE NARSINGRAO} NANDIKOIYDA

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W.P.No.4838 OF 2025

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ORDER,^{(per Hon'bleSri Jttstice P.SamKoshy)}

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Heard Ms. K. Prabhabati,^{learned counselrepresenting} Mr. A.V.Raghu^{Ram, leamedcor1nsel for the petitioner and} Ms. J.Sunitha,^{leamed Junior Standing Counselfor the Income} Tax Department^{for respondent No.l. Perusedthe record'}

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This is a writ^{petition where the proceedings are either} challenged to the^{notices which wefe issuedunder Section 148A} and 148 of the^{lncomeTax Act, 196l (for short 'the Act')or the} assessment orders^{those have been passed under Section147 of} the Act which^{have been assailed.}

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This writ petition^{is being tatfnup today only on one of the} grounds, that the notices^{issuedunder Sectionl48A of the Act} and the subsequent initiation^{of propeedingsunder Section148 of} the Act by the^{jurisdictionalAssessingOfftcer, whereas in terms} of the amendment that^{was brought to the Income Tax Act by way} of Finance Act,^{2021 w'e.f.,01.04.2021 onwards,proceedings}

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under Section l48A of the Act as also under Section 148^{of the} Act ought :o have also been issued and^proceeded in a faceless manner,

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The contention of the petitioner is that the issue of proceedingri being in violation of the Finance Act,202l i.e., the impugned rrotices under Section 148A and Section¹⁴⁸ of^{the Act} not being issued in a faceless manner, have already been dealt^with and decide,d by this Court in the case of KANKANALA RAVINDRA REDDY vs. INCOME-TAX OFFICERT decided ot 14.09.2A23 whereby a batch of writ petitions were allowed and the proceedings initiated under Section l48A as also under Section 148 of the lrct were held to be bad with consequential reliefs on the ground of it being in violation of the provisions of Section l51A of the Act reacl with Notification 1812022 dated 29.03 2022. The said judgment pzLssed by this Court has also been subsequently followed in a large nrmber of writ petitions which were a[lowed on similar terms.

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'l(2023)^{156 taxrnann.corn178 (Telangana)l}

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Down the line, we^find that^{the sameissue has also been} decided against the^Revenue by^{various High Courts i.e.,} by the Bombay High Court in the^case of^IIEXAWARE TECHNOLOGTES LTD.,^{VS. ASSISTANT COMMISSIONER} OF INCOME^TAX &^{OTHERS2, pauhati High Court in the case} of RAM NARAYAN^{SAH vs. UNION OF INDIA3,Punjaband} Haryana High Court in^{the case of} JATINDER^{SINGH BANGU} vs. UNION OF INDIA4, and^{TelanganaHigh Court in the case of} SRI VENKATARATVIANA^{REDDEPATLOOLAVS. DEPUTY}

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COMMISSIONER OF^{INCOMETAX5wherethe issue was in} respect of intemational^{taxation,Bopbay High Court in the case of} ABHIN ANILKUIVIAR^{SHAH vsi INCOMETAX OFFICE&}

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INTERNATIONAL^{TAXATION6which is again on intemational} taxation and central^{circle, High Court of Himachal Pradesh in the} case oI GOVIND^{SINGH vs. INCOME TAX OFFICERT,} Cujarat High Court^{inthe case ofMANSTIKIIBHAI}

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DAIfYABIHAI RADADIYA vs. TNCOME T.AX OFFICE& WARD 3(3Xt8, Jharkand High Court in the case of SIfYAM SUNDAR SAW vs. UMON OF INDIAe, Rajasthan High Court in the case of SHARDA DEVI CHHAJER vs. INCOME TAX OFFICER & ANOTHER and batch of writ petitionsro which stood decided on 19.03.2024. Similar views have also been taken by the Division Bench of Calcutta High Court in the case of GIRDHAFI GOPAL DALMIA vs. UNION OF INDIA & ORS (M.A,T 169t0 of 2023, decided on 25.09 .2024.

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Even though the same issue having been decided by a large number of l{igh Courts, we are still confronted with large filing of identical matters on daily basis ranging betwcen 5 to l0 writ petitions. 1'hat upon the instructions being sought fiom the Deparhnent, they have been taking a solitary ground that the decisioa of the Bombay High Court in the cast ot Hexaware Technologirzs Ltd, (2 suprai as also the one u'hich has been decided by this Court in the case of Kanakala Ravindra Reddy

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'2024^{SCCCrnline Guj 4012} '2025^{SCC()nline Jhar287} 'o 12023^{: RJ-J D :49 84-DB} l

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(1 supra) has been subjected to Qhallenge in a Special^Leave Petition i.e., SLP No.3574 of 202! before^{the Hon'bleSupreme} Court and the Hon'ble Supreme Court is^{seized of the matter.} In addition, there are about 1200 SIIPs^{also filedarising out ofthe} same issue being decided^{by various High Courts.}

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To a query being put to the^{lepmedcounsel for the Revenue,} they have categorically^{acceptedthe 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 petitionsof} identicat nahrre are being^{pited up} lefore^{this Bench on daily basis} and the pendency is^{gettingincreasedon matterwhich otherwise} has already been dealt and^decided [y^{this very High Court itself.}

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On the one hand, even^{though the order of this Court that} was passed as earty as on^{14.09.2Q23 and more 16 monthshave} lapsed, till date, we do^{not find any remedialstepshavingbeen} taken by the lncome^{Tax Departmqntto take appropriatesteps to} either hold back issuance^{of notice under Section 148,4'and under} Section 148 ol the Act by^{the junsdictional Assessing OfEcer,} rather the authorities concemed ln the teeth o[ series of decisions

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by all thr: major High Courts in India are continuously still initiating proceedings under Section l48A of the Act and also initiating proceedings under Section 148 of the Act in contravention to the amendments brought into the Income Tax Act pursuantto the Finance Act,2020 as also the Finance Act202l .

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Upolr a query being put as to why can't this writ petition be disposed o;'in the teeth of the decision rendered by this Court in the case of Kanakala Ravindra Reddy (l supra), leamed Standing Counsel for the Income Tax Department contends rhat those would unnecessarily burden the Income Tax Departmcnt where they would be required to file equal number of S l-l)s before the Hon'ble Su preme Court and it would be further burdening the exchequer c'f the Union of India. It was also the crrntention ol the leamed Standing Counsel that no prejudice would be caused to rhe interest of the petitioners in case if this writ perition is kept pending tilt the finirlization of the SLPs pending befiore the Hon'ble Supreme Cc,urt and the fact that the petitioner is already enjoying the benefit c,f interim protection. Nonetheless, on tlre earlier query o[this Courr. as to why the Income Tax Department have not come out with a rrechanism to issue appropriate instruct ions or to take

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appropriate steps in ensuring that^{proceedings underSection l48A} of the Act as also the^{assessmentofders underSection 148 of the} Act are kept in a hold in the light ofthe decisions^{dedcidedby the} various High Courts, it was submftted by^{the leamedStanding} 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} limited to any of these^{jurisdictional High Courts}

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As a result of which, what^{we are facingis steepincreaseof} litigation day in and day out even^{ttiough variousorders have been} passed by this High Court allowing^{writ petitions on th€ very same} issue. The Income Tax authorities loncerned are still even now in 2025 also initiating^{proceedings in contraventionto the provisions} of Section l51A of the^{Act and as} 4^{result by now, more than 600} to 700 petitions have been^{already got pitedup before this High} Court on an issue^{whichotherwisestands squarely covered by the} judgment of this Court in the case ol Kanakala Ravindra Reddy (1 supra). What is also surPrisinq^{is the lact that though while} allowing the writ^petitions in^{the case of KanakalaRavindra} Reddy (l supra), the^{Division Benph whilereserving the 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^Revenuefor initiating fresh proceedings strictly in accordance^{with the amended} provisions of the Act, as amended by the Finance Act, 2020^and the Finance \ct,2021. The petitioner assessee would^{be entitled to} challenge or raise the other legal objections if the Rcvenue initiates fresh proceedings. The Department has made nc, endeavourⁱⁿ availing the r;aid 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 hetd to be bad.

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[t appt:ars that because ofthe aforesaid libertl' 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 t,f the same by protracting these proceedings which would enable them to meet the limitation that would otherwise come in the waY. I ikewise, if the writ petition is kept pending for a considerable long^period of time and finally ar: a later stage if the Hon'ble Supreme^{( louft} confirms the decision taken by this High Court as also by^{the other High} Courts in which the SLPs are still pending, tht'^{lncome I'ax}

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Department would^get the advantagq^{of the libertythat is otherwise} protected in favour of the Revenue for^{initiation of fiesh} proceedings from the disposal of thepe^{matters at a much laterstage} which would be advantageous and^{beneficialto the Revenue and} would be equally disadvantageous^{ahddetrimentalso far as interest} of the assesses are^{concerned.As a consequence,the Income Tax} Department^gets an extended^{periodof time for initiationof fresh} proceedings.

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The alarming trend^{of docketexplosion in this Court,despite} the clear^precedent set^{in Kanakala RavindraReddy (l supra),is a} mafter of^gftIve concem.^{The lncorpeTax Department'spersistent} initiation of fresh^{proceedings,disregardingthe established judicial} pronouncements, has led to^{an unprecedented surge in litigation} with over 600-700^{petitionspiting up on the same issue'This} deliberate approach^{not only undelmines the principle of judicial} precedent but also strains the^{judicialresources unnecessarily'The} Department's strategy of^{awaitingthe SupremeCourt's decisionon} pending SLPs while^{continuingto initiate freshproceedings} appeffs to be a^{calculated move to buy time and circumvent} limitation periods, rather^{than adfering to the established legal}

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

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Anolher 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 ensuriog that proceedings under Sections 148-A and 148 should not have been issued in a faceless mirnner, at least till the Hon'ble Suprerne Court decide the twelve hunlred (1200) odd SLPs which it is already seized olor, at least the Income Tax Department should have tbund out some remedial sleps to ensure that wherever the authorities intend to initiate pror:eedings under Sections 148-A and 148, other than in a fhceless 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 decision il at atl

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has to be taken, has to be taken for the whole of India; and which otherwise has to beby way ofa policy decision and that too at the level of Central Board of Direct Taxes. Though the leamed Standing Counsel for the Income Tax Department contended that the Delhi High Court dismissed a writ petition of similar narure, on the one hand when the High Court is struggling to reduce its pendency, such notices which are under challenge in this writ petition are forcing the assessee to knock the doors of this High Court resulting in filing of hundreds of new writ petitions which in the long run not only affects the disposal o[ the writ petitions but also consumes substantial time of the Bench in hearing these matters again and again on 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 seized of the matter has been reluctant in granting any interim protection to the Income Tax Deparhnent. Yet, the authorities concemed at the State level are not ready to accept thE verdict passed by a majority ol High Courts of different States or1 the same issue; and to make things further worse, the Income Tax Department is showing audacity by issuing notices continuously under Sections I48-A and

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148 through the jurisdictional Assessing Officer whereas it ougtrt

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to have been only in the faceless manner.

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In the case of BANK OF INDIA vs. ASSISTANT

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COMMISiSIONER, INCOME TAX1t, 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 thirt 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. Paridwalla has rightly drawn out attention to the decisic,n of this Court in Commissioner of lncome Tax vs. Smt. Godavaridevi Saraf'2 as also the recent decision of the coordinale Bench of this Court in Samp Furniture (P) Ltd. v. lTOt3 of which one of us (Justice G.S. Kulkami) was a member, wherein the Cc,ur1 categorically observed that the Revenue having not 'accepted" the judgment of the High Court would not mean that till the sarne 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 Gorporation Ltd.14, the Court observed that the approach of the officials of Revenue of treatinq decisions being "not acceptable" was criticized by the Suprenre Court ln such decision, following are the relevant observirtions made by the Supreme Court.

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'l ttZOzsl^{l-/0 taxmann.com 422 (Bombay)l} '' 1t9281^{I t I ITR 589(Bombay)}

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" 12OZ+1^{[65 taxrnann.com} 581/300 Taxman 452 (Bombay)

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'* 1t9921^{taxrnann.coml6155} ELT 433 (SC)

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"6. Sri ReddY is PerhaPS^{rdfrt in saYlng that the} officers were^{not actuated} by any mala^{fides in} passing the impugned^{orflers.TheYPerhaPs} genuinely felt that the^{claim (} I^{the assesseewas not} tenable and^{that, if it was} hccepted,^{the Revenue} would suffer.^{But what Sri R€} lddy^{overlooks is that we} are not concemed^hereul lith tne conectness^or otherwise of^theirmnclusl l* o, ot^{any factual} malafides but^{with the fact} the officers,^{in reaching} in their conclusion,^bY4asse t\itlo appellate^ordersin ich were Placed^before regard to the^sameissue eals) and the^{other of} them, one^{of the Collector(} the Tribunal.^{The HighCou} has, in^{our view,rightlY} criticized this^{conductof the} Assistant^{Collectorsand} caused^{bY the failure} the harassment^{to the asses} of these officers^{to give} to the orders^of authorities^{higher to them in} e appellate^hierarchy.lt hasized that^{it is of} cannot be^{too vehemently} utmost imPortance^that' ln disposing^ofthe quasijudicial issues^{bebre t} emr revenue^officersare bound by the^{decisions of} appellate^authorities The order of the^APpellte is binding on^the Assistant^{Collectors workirEwithinhis jurisdictionand} the order^{of the Tribunalis} inding^{upon the Assistant} Collectors aM^the Collectors^whofunction under the^{jurisdictionof the} ribunal.^The Principles^of judicial disciPline require^{tht the orders of the higher} appellate^{authorities shouldbe folbwed unreservedly} . The^{merefact that the} by the subordinate^a 'rs not "acceptable" to order of the^{aPPellate a} the department -^{in itself} n obiectionable Phrase - and is the^{subiect matter} an appeal^{can furnishno} unless its^operationhas ground for not^following t court.^{lf this healthy} been^{susPendedbY a com}

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

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We have dealt with this aspect at some length, because it has been suggested by the leamed tr,dditional Solicitor General that the observations nrade by the High Court, have been harsh on the offlcers. lt is clear that the obseNations of the High C:ourt, seemingly vehement, and apparently 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 k) the Revenue. We would like to say that the department should take these observations in the proper spirit. The observations of the High Court slould be kept in mind in future and the utmost regard s'rould be^paid by the adiudicating authorities and the appellate authorities to the requirements of^judicial dlscipline and the need for giving effect to the orders ol the higher appellate authorities which are binding on them."

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Wha: is worrying this Bench more is the fact that an endeavour is being made whole heartedly to ensure not to generate further litip ation on issues which have been laid to rest by a large number of High Courts all of whom have taken a coosistent stand that the action of the lncome Tax Department being violative of the

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Finance Act,2020 and Finance Act, 2011:Irbw,rinbtdbr 6 protect the interest of the Revenue as also that of the assess€, it would be trite at this juncture, if we dispose of the writ petition with an observation/direction that the dispos4l ofthe instant writ petition in terms of the judgment rendered by fhis High Court in the case of Kankanala Ravindra Reddy (l supra) shall however be subject to the outcome of the SLPs which were filed by the Income Tax Department and which is pending copsideration before the Hon'bte Supreme Court.

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In the given facts and circunfstances, this Bench is of the considered opinion that unless and {ntil we do not timely dispose of matters which are squarely.ou"..h by the decision of this Court and which stands fortified by the decisions of the various other l{igh 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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So far as the interest of the Revenue is concemed, we are of the considered opinion that the intereFt of the Revenue has already been considered and protected, as has been observed in paragraphs

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36,37 attl:l8 cr'tile o.ioi^{r.i:rl.lh^} fc; ready referer,c.e, is reproduce<i

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hereunder:

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3ri. For all the aforesaid reasons, the impugned notices issued and the proceedings drawn by the respondentDepartment is neither tenable, nor sustainable. T1e notices so issued and the procedure adopted being p(rr se illegal, deserves to be and are accordingly set ar;ide/quashed. As a consequence, all the impugned orders^{getting quashed,} the consequential orders passed bv the respondent-Depa(ment pursuant to the notices issued under Section 147 and^'lz18 would also get quashed and it is ordered accordingly. The reason we 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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3^2. The^preliminary objection raised by the petitioner is sL stained and all these writ petitions stands allowed on th s very^{jurisdictional} issue. Since the impugned notices arrd orders are getting quashed on the point of ju|isdiction, we are not inclined to proceed further and de,cide the other issues raised by the pelitioner which stilnds reserved to be raised and contended in an aF,propriate proceedings.

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3{}. Since the Hon'ble Supreme Court had, in the case of Ashish Agarwal, supra. as a one-time measure exercising the powers under Article 142 of the Constitution of lndia,^permitted the Revenue to proceed under the subslituted provisions, and this Court allowing tht. petitions only on the procedural flaw, the right

I t

!EEa@E:-

conferred on the Revenue ld remain , reserved to lryou proceed further if they so vriant from the stage of the order of the Supreme Coqft in the case ofAshish Agarwal, supra.

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We would only further like tp make observations that since we are inclined to dispose of the in$tant writ petition, conscious of the fact that the earlier order of tJris High Court in the case of Kanakala Ravindra Reddy (l ruqra) is subjected to challenge before the Hon'ble Supreme in SLP No.3574 of 2024, preferred by the Income Tax Dep ent, we make it clear that allowing of the instant writ petitio{ is subject to outcome of the aforesaid SLP preferred by the Rev ue against the decision of this High Court in the case of Kanakala Ravindra Reddy (l *pra). This, in other words, would mean ttfat either of the parties, if they so want, may move an appropnate Petition seeking revival of this writ petition in thc light of the dec sion of the Hon'ble Supreme Court in the pending SLP on the verS same issue.

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Accordingly, the instant wrjt petition stands allowed in favour of the assessee so far as the issue of jurisdiction 1S concerned. As a consequence, the impugned notice under challenge under Sections 148-A andl 148 stands set aside/quashed.

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The consequential orders, if any, also stand set aside/quashed in

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similar tenns as have been passed by this High Court in the case of

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Kankanalu Ravindra Reddy (l supra). There shatl 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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D/- L. VIJAYA LAXMI
A TANT REGIST

/ffRUE COPY//

SECTION OFFICER

To,

Assessment Unit, National Faceless Asressme,it Centre. lncome Tax Departmerrl. Ministry .of Finance. Room No. 4O1, 2"d Fbor, E-Ra;p; Jawaharlal Nehru Stadium, Delhi - 110 003.

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The lncorne Tax Officer Wa! a(]), Signature Towers, Opp. Botanical Gardens, l(ondapur. 1-lderabad - 50b084.^"

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Punjab National Bank, lN:B HO, Ground Floor, Wing Sector 10. Amberhai, South Wer;t Delhi-1 10075. Rep. by its Chairman a_nC ruianaging Oirect6n^- -'

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lndustrial l)evelopment Bank of lndia (lDBt) 22.a t:toot, ii*"ation Cefi, f Ogf lower. Colaba S.O., Mumbai - 400005, Rep. by its Chairman and Managing

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Director.

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