Andoor Primary Agricultural Co-Operative Credit Society Ltd Y 199 v. Union Of India Represented By The Secretary

1 WP(MD)No.32923 of 2025 etc., BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT DATED : 21.11.2025

CORAM

THE HONOURABLE MR.JUSTICE G.R.SWAMINATHAN WP(MD)Nos.32923 to 33003 of 2025 and WMP(MD)Nos.25980 to 25989, 25979, 25990 to 25992, 25994 to 26005, 26008 to 26010, 26013 to 26018, 26020, 26023 to 26026, 26034, 26060, 26064, 26070, 26074 26081, 26084, 26089, 26092, 26094 to 26100, 26103, 26105 to 26111, 26113, 26115, 26117, 26121 to 26125, 26127, 26128, 26131, 26133 to 26135, 26137, 26138 and 26141 of 2025 Andoor Primary Agricultural Cooprative Credit Society Ltd Y 199, Rep.by its Secretary, Mr.G.John Livingston, Andoor, Kanyakumari District.

... Petitioner in WP(MD)Nos.

32923 & 32924 of 2025 Y-126 Aruvikarai PACCS Limited ... Petitioner in WP(MD)No.

32925 of 2025 2925 Andoor Primary Agricultural Co-operative Credit Society ... Petitioner in WP(MD) No.32926 of 2025 Andoor Primary Agricultural Cooperative Credit Society Represented by Secretary Mrs. Thanka Leela N, Attoor, Thiruvattar, Kanyakumari - 629177, Tamil Nadu.

... Petitioner in WP(MD) No.32927 of 2025 Andoor Primary Agricultural Cooperative Credit Society ... Petitioner in WP(MD) No.32928 of 2025 1/43

2 WP(MD)No.32923 of 2025 etc., Brammapuram PACCS Ltd. Y 210 Represented by Secretary Mrs. Usha David Johnson, 37/7BA, Ammu Nivas, Ramaswamy Kovil, Thuckalay H.O Kalkulam, Kanyakumari - 629175, Tamil Nadu.

... Petitioner in WP(MD) No.32929 of 2025 Brammapuram Paccs Ltd. Y 210 Represented by Secretary Mrs. Usha David Johnson, 37/7BA, Ammu Nivas, Ramaswamy Kovil, Thuckalay H.O Kalkulam, Kanyakumari - 629175, Tamil Nadu.

... Petitioner in WP(MD) No.32930 of 2025 Changai Primary Agricultural Cooperative Credit Society Ltd Y 185 Represented by Secretary, Mr.

Robinson Chellaian,13-185, Changai Kanjiracode Post, Kanyakumari - 629155, Tamil Nadu ... Petitioner in WP(MD) No.32931 of 2025 The Charoor PACCS Ltd., ... Petitioner in WP(MD) No.32932 of 2025 Elanchirai Paccs Limited Y245 Represented by Secretary Mrs.

Rajila.R, Elanchirai, Kanyakumari-629001, Tamil Nadu ... Petitioner in WP(MD) No.32933 of 2025 Gandhiji Memorial Co-Operative Credit Society Ltd Y 175, Represented by Secretary Mrs. Umarani Gnanam 49, Thazhirpuram Street, Vadasery Nagercoil, Kanyakumari-629001, Tamil Nadu ... Petitioner in WP(MD) Nos.32934, 32935 & 32936 of 2/43

3 WP(MD)No.32923 of 2025 etc., Ittakavely Primary Agricultural CoOperative Credit Society Ltd Y 234 Represented by Secretary Mr.Jabanazer Hentry, Ittakavely Cheruppaloor, Kanyakumari-629161,Tamil Nadu.

... Petitioner in WP(MD) Nos.32937, 32938 & 32939 of 2025 Thejawahar P A C C S Ltd Represented by Secretary Mrs. Soba.S 49,Thazhirpuram Street, Vadasery Nagercoil, Kanyakumari-629001, Tamil Nadu ... Petitioner in WP(MD) No.32940 of 2025 K.K.Dist.Judicial Department Employees Co-Op Thrift and Credit Society,Represented by Secretary Mr. Rajesh.R, District Court Campus Court Road, Nagercoil, Kanyakumari 629001 ... Petitioner in WP(MD) Nos.32941 & 32942, 32943 of Kalkulam Co-Op Store Ltd No-2048 Represented by Secretary Mr. T.Padmakumar, 17/14 Marketroad Thuckalay,Kanyakumari-629175, Tamil Nadu.

... Petitioner in WP(MD) No.32944 of 2025 1281 Kattathurai P A C C S Represented by Secretary Mr. T Christopher Selva Kumar Kattathurai P.O, Kanyakumari-629158, Tamil Nadu.

... Petitioner in WP(MD) No.32945 of 2025 3/43

4 WP(MD)No.32923 of 2025 etc., The Kattimancode Primary Agricultural Co-operative Credit Society Ltd Y 76 Represented by Secretary, Mrs. C Helen Pitty, Kattimancode, Kalkulam, Kanyakumari- 629102, Tamil Nadu.

... Petitioner in WP(MD) Nos.32946, 32947, 32948 of Y 105 Keezhkulam Anavilai Primary Agricultural Co-Operative Credit Society L11 Represented by Secretary Mr.John Pence J, Keezhkulam S.O Keezhkulam, Kanyakumari- 629193 Tamil Nadu ... Petitioner in WP(MD) Nos.32949 & 32950 of 2025 Kulasekharam P A C C S Ltd Y 256, Represented by Secretary Mrs.Nanthini G, Kovilai, Arasamoodu Kulasekharam, Kanyakumari-629161 Tamil Nadu.

... Petitioner in WP(MD) No.32951 of 2025 Kumarankudy Primary Agricultural CoOperative Credit Society Ltd No Kv 133, Represented by Secretary Mrs. R. Rajashree, Kumarankudy Chenkody P.O, Kanyakumari-629602 Tamil Nadu ... Petitioner in WP(MD) No.32952 of 2025 Y-232 Kurunthencode Primary Agricultural Co-operative Credit Society Ltd Represented by Secretary,Mr. Ganesan Prammamuthu Ramaiyah, Kurunthencode, Peyankuzhi B.O Kalkulam, Kanyakumari- 629809, Tamil Nadu ... Petitioner in WP(MD) Nos.32953, 32954, 32955 of 4/43

5 WP(MD)No.32923 of 2025 etc., Lekshmipuram P.A.C.C.S Ltd No 1560 Represented by Secretary, Mrs. Nirmala Paul Das, Konamkadu,Lekshmipuram, Kanyakumari-629703, Tamil Nadu.

... Petitioner in WP(MD) Nos.32956, 32957, 32958 of Madathattuvilai Primary Agricultural Co-Operatives Society Represented by Secretary Mrs. Geetha E, No.1/13, Near Evening Market, Villukuri, Kanyakumari- 629180, Tamil Nadu ... Petitioner in WP(MD) No.32959 of 2025 Manavilai P A C C S Ltd Y 144 Represented by Secretary Mrs.Marygilda Bai Rajaseharan Manavilai Friday Market P.O., Kanyakumari- 629203, Tamil Nadu.

... Petitioner in WP(MD) Nos.32960, 32961, 32962 of Nagercoil Municipal Employees Coop Thrift And Credit Society Ltd Represented by Secretary, Mr. V Muthukumar,Nagercoil, Kanyakumari-629001, Tamil Nadu ... Petitioner in WP(MD) Nos.32963, 32964, 32965 & 32967 of 2025 1 Nagercoil Municipal Employees Coop Thrift And Credit Society Ltd Represented by Secretary, Mr. V Muthukumar,Nagercoil, Kanyakumari-629001, Tamil Nadu

2. The Central Board of Direct Taxes CBDT, Represented by its Chairman, North Block, Delhi ... Petitioner in WP(MD) Nos.32966 of 2025 5/43

6 WP(MD)No.32923 of 2025 etc., Palliyadi Paccs Limited Y177 Represented by Secretary,Mrs. Kezia Rajkumar,Palliyadi,Kalkulam, Kanyakumari- 629102, Tamil Nadu ... Petitioner in WP(MD) Nos.32968, 32969 & 32970 of 2071 Ponmanai Primary Agricultural Cooperative Credit Society Limited Represented by Secretary Mrs.Pushaparani Robert Wilson Ponmanai, Kanyakumari-629161 Tamil Nadu.

... Petitioner in WP(MD) Nos.32971 & 32972 of 2025 The Pwd Employees Co-Operative Thrift and Credit Society Limited No.

Kv-6, Represented by Secretary Mr.L Micheal Retnam, Thuckalay P.O., Kanyakumari- 629175, Tamil Nadu ... Petitioner in WP(MD) Nos.32973, 32974, 32975 & 32976 of 2025 Ramavarmanchirai Primary Agriculture Credit Co-operative Society Ltd Y 100 Represented by Secretary,Mr. Viju Viyagappan,Vilavancode,Kanyakumari629152, Tamil Nadu ... Petitioner in WP(MD) Nos.32977, 32978 of 2025 Primary Agricultural Co-operative Credit Society Ltd Reethapuram Represented by Secretary, Mrs.

Sukitha Mary, Reethapuram, Vilvancode, Kanyakumari- 629159, Tamil Nadu.

... Petitioner in WP(MD) Nos.32979, 32980, 32981 of 6/43

7 WP(MD)No.32923 of 2025 etc., Thazhakkanvilai Primary Agricultural Co-operative Credit Society Ltd 170 Thazhakkanvilai Primary Agricultural Co-Operative Credit Society Ltd 170 Represented by Secretary Mr. Sasikumar, Chinna Nadar Thazhakanvilai, Mullankanavilai P.O.,Kanyakumari- 62 ... Petitioner in WP(MD) Nos.32982, 32983 of 2025 Thazhakudy Primary Agricultural Cooperative Credit Society Ltd Represented by Secretary Mr. D Dhas Thazhakudy, Kanyakumari- 629901 Tamil Nadu ... Petitioner in WP(MD) Nos.32984, 32985 of 2025 Theroor Paccs Ltd Y 334 Represented by SecretaryMr.B HariharanTheroor P.O,Kanyakumari629704, Tamil Nadu ... Petitioner in WP(MD) No.32986 of 2025 Y.201. Thickanamcode Paccs Ltd.

Represented by Secretary Mrs.Vijila.T Thickanamcode, Kanyakumari- 629402 Tamil Nadu ... Petitioner in WP(MD) No.32987 of 2025 Thirparappu Paccs Ltd 2490 Represented by Secretary Mrs. A Merla Sonia, Thirparappu, Kanyakumari- 629161, Tamil Nadu ... Petitioner in WP(MD) Nos.32988, 32989, 32990 of Thirunanthikarai Paccs Ltd 1851 Represented by Secretary Mr.Maheswaran Nair Madhavan Pillai Kulasekharan P.O., Kanyakumari- 629161, Tamil Nadu ... Petitioner in WP(MD) Nos.32991, 32992 of 2025 7/43

8 WP(MD)No.32923 of 2025 etc., 674, Thiruvattar Primary Agricultural Co-opeative Credit Society Represented by Secretary Mrs. Usha Kumari M, Thiruvattar Kanyakumari District.

... Petitioner in WP(MD) No.32993 of 2025 Vadasery Co Op Credit Society Ltd No Y 4 Represented by Secretary Mrs. Rajalekshmi Padmavathi, Pioneer Street, Kanyakumari- 629001, Tamil Nadu ... Petitioner in WP(MD) Nos.32994, 32995, 32996, 32997 of 2025 of 2025 The Vattavilai Primary Agricultural Cooperative Credit Society Represented by Secretary Mr. P Paul Dickshit Singh, 20/162 Vattavilai, Thickanamcode, Kanyakumari- 629804, Tamil Nadu ... Petitioner in WP(MD) No.32998 of 2025 Veeranarayanasery Paccs Ltd No Y 30 Represented by Secretary Mrs. Ambika Duraiswamy, AloorGramam, Kanyakumari- 629801, Tamil Nadu ... Petitioner in WP(MD) No.32999 of 2025 The Vendalicode Paccs Ltd No.Y-283 Represented by Secretary Mrs. A.Prema Latha, Vendalicode P.O Kanyakumari- 629161, Tamil Nadu ... Petitioner in WP(MD) No.33000 of 2025 Venkanji Primary Agricultural Cooperative Bank Represented by Secretary Mrs.Nirmala C Venkanji Vilavancode, Kanyakumari- 629160 Tamil Nadu ... Petitioner in WP(MD) Nos.33001, 33002 of 2025 8/43

9 WP(MD)No.32923 of 2025 etc., Vilathurai Paccs Limited Y 167 Represented by Secretary Mr.Ayyapadas Arjunan Vilathurai Kappukadu S.O,Kunnathoor Kanyakumari- 629162, Tamil Nadu ... Petitioner in WP(MD) No.33003 of 2025 Vs.

1.Union of India, Rep.by the Secretary, Ministry of Finance, Income Tax Department, North Block, New Delhi - 110 001.

2.The Central Board of Direct Taxes, (CBDT), Rep.by its Chairman, North Block, New Delhi - 110 001.

3.Ministry of Cooperation, Government of India, Rep.by its Secretary, Atal Akshay Ujra Bhawan, CGO Complex, Lodhi Road, New Delhi.

4.The Chief Commissioner of Income Tax, Office of the CCIT, Bibikulam, Madurai - 625 002.

... Respondents Prayer in WP(MD)No.32923 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1066391193(1) dated 04-07-2024 for the AY2019-20 and quash the same and consequently direct the 4th 9/43

10 WP(MD)No.32923 of 2025 etc., 139(1) in line with CBDT Circular No.13/2023 dated 26-07-2023 and 14/2024 dated 30-10-2024.

Prayer in WP(MD)No.32924 of 2025:

to issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1066391409(1) dated 04-07-2024 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32925 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2025-26/1075574944(1) dated 09-04-2025 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further order Prayer in WP(MD)No.32926 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records 10/43

11 WP(MD)No.32923 of 2025 etc., pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1071579926(1) dated 26-12-2024 for the AY2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32927 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1064786464(1) dated 10-05-2024 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32928 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1071580096(1)dated 26-12-2024 for the AY2020-21 and quash the same and consequently direct the 4th 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 11/43

12 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32929 of 2025:

To issue aa WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2025-26/1075446860(1) dated 03-04-2025 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32930 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2025-26/1075446487(1) dated 03-04-2025 for the AY2020-21and quash the same and consequently direct the 4th 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32931 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1069871091(1) dated 23-10-2024 for the AY2020-21and quash the same and consequently direct the 4th 12/43

13 WP(MD)No.32923 of 2025 etc., 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 aand pass such other or further orders. Prayer in WP(MD)No.32932 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4 respondent bearing DIN ITBA/COM/F/17/2024-25/1067185125(1)dated 31-07-2024 for the AY2019-20and quash the same and consequently direct the 4 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32933 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1071007745(1) dated 09-12-2024 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32934 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN 13/43

14 WP(MD)No.32923 of 2025 etc., ITBA/COM/F/17/2024-25/1063932416(1) dated 05-04-2024 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32935 of 2025:

To issue aa WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1063932648(1) dated 05-04-2024 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32936 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1063932109(1) dated 05-04-2024 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. 14/43

15 WP(MD)No.32923 of 2025 etc., Prayer in WP(MD)No.32937 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072987506(1) dated 06-02-2025 for the AY2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32938 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067472958(1) dated 09-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32939 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4 respondent bearing DIN. ITBA/COM/F/17/2024-25/1067473459(1) dated 09-08-2025 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 15/43

16 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32940 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067652478(1) dated 14-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32941 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1073616925(1) dated 24-02-2025 for the AY2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32942 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1073617371(1) dated 24-02-2025 for the AY 16/43

17 WP(MD)No.32923 of 2025 etc., 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32943 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1072990874(1) dated 06-02-2025 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32944 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067475268(1) dated 09-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th respondent to condone the delay in filing return of income for AY 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32945 of 2025:

17/43

18 WP(MD)No.32923 of 2025 etc., To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067184880(1) dated 31-07-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32946 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1073492379(1)dated 20-02-2025 for the AY 2018-19and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32947 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1073492548(1) dated 20-02-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 18/43

19 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32948 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1073492949(1) dated 20-02-2025 for the AY 2020-21and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32949 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072017526(1) dated 09-01-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32950 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1069247015(1) dated 30-09-2024 for the AY 2020-21 and quash the same and consequently direct the 4th 19/43

20 WP(MD)No.32923 of 2025 etc., 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32951 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067194431(1) dated 31-07-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32952 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072927553(1) dated 05-02-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass such other or further orders. Prayer in WP(MD)No.32953 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records 20/43

21 WP(MD)No.32923 of 2025 etc., pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067112122(1) dated 29-07-2024 for the AY 2018-19 and quash the same and consequently direct the 4th respondent to condone the delay in filing return of income for AY 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32954 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067174952(1) dated 31-07-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32955 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067175382(1) dated 31-07-2024 for the AY 2020-21and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 21/43

22 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32956 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067473691(1)dated 09-08-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32957 of 2025:

To issue a Writ of OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067473885(1)dated 09-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32958 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067474140(1)dated 09-08-2024 for the AY 2020-21and quash the same and consequently direct the 4th 22/43

23 WP(MD)No.32923 of 2025 etc., 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32959 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067458549(1)dated 08-08-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32960 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067171095(1) dated 31-07-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32961 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN 23/43

24 WP(MD)No.32923 of 2025 etc., ITBA/COM/F/17/2024-25/1065983048(1) dated 24-06-2024 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32962 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant the impugned respondent bearing DIN ITBA/COM/F/17/2024-25/1067217535(1)dated 01-08-2024 for the AY 2021-22and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32963 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072989244(1)dated 06-02-2025 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. 24/43

25 WP(MD)No.32923 of 2025 etc., Prayer in WP(MD)No.32964 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072988978(1)dated 06-02-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32965 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072965469(1)dated 06-02-2025 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32966 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1072990743(1)dated 06-02-2025 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 25/43

26 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32967 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1073615062(1)dated 24-02-2025 for the AY 2022-23and quash the same and consequently direct the 4th 2022-23by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32968 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067170216(1)dated 31-07-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32969 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067170496(1) dated 31-07-2024 for the AY 26/43

27 WP(MD)No.32923 of 2025 etc., 2020-21and quash the same and consequently direct the 4th 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32970 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1067170708(1)dated 31-07-2024 for the AY 2021-22and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32971 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1074035238(1)dated 05-03-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32972 of 2025:

27/43

28 WP(MD)No.32923 of 2025 etc., To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074035933(1)dated 05-03-2025 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32973 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074554143(1) dated 17-03-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32974 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074554834(1)dated 17-03-2025 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 28/43

29 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32975 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074555207(1) dated 17-03-2025 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32976 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074555626(1)dated 17-03-2025 for the AY 2022-23and quash the same and consequently direct the 4th 2022-23by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32977 of 2025:

to issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074448030(1)dated 13-03-2025 for the AY 2020-21 and quash the same and consequently direct the 4th 29/43

30 WP(MD)No.32923 of 2025 etc., 2020-21by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32978 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1074448583(1)dated 13-03-2025 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32979 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1066602361(1)dated 11-07-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32980 of 2025:

to issue a Writ of CERTIORARIFIED MANDAMUS calling for records 30/43

31 WP(MD)No.32923 of 2025 etc., pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1066602664(1)dated 11-07-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32981 of 2025:

to issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1066390198(1)dated 04-07-2024 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32982 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2023-24/1061517934(1)dated 26-02-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 31/43

32 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32983 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1063933692(1)dated 05-04-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32984 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1068444951(1)dated 09-09-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32985 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DINITBA/COM/F/17/2024-25/1068445359(1)dated 09-09-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 32/43

33 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32986 of 2025:

To issue a Writ of CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN ITBA/COM/F/17/2024-25/1070886799(1) dated 04-12-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32987 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1072987904(1) dated 06-02-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32988 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN 33/43

34 WP(MD)No.32923 of 2025 etc., ITBA/COM/F/17/2024-25/1071401591(1)dated 20-12-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 139(1) in line with CBDT Circular No.13/2023 dated 26-07-2023 and 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32989 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1071401755(1) dated 20-12-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32990 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1071401998(1) dated 20-12-2024 for the AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order 34/43

35 WP(MD)No.32923 of 2025 etc., Prayer in WP(MD)No.32991 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN.ITBA/COM/F/17/2024-25/1067653145(1) dated 14-08-2024 for the AY 2018-19 and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32992 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067652798(1) dated 14-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th respondent to condone the delay in filing return of income for AY 2019-20 by the petitioner. under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32993 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN.ITBA/COM/F/17/2024-25/1071627295(1) dated 27-12-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 35/43

36 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32994 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067647519(1) dated 14-08-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32995 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067651021(1) dated 14-08-2024 for the AY 2020-21 and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32996 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN.ITBA/COM/F/17/2024-25/1072465661(1) dated 23-01-2025 for the 36/43

37 WP(MD)No.32923 of 2025 etc., AY 2021-22 and quash the same and consequently direct the 4th 2021-22 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.32997 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1067652159(1) dated 14-08-2024 for the AY 2022-23 and quash the same and consequently direct the 4th 2022-23 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD)No.32998 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1065991577(1) dated 25-06-2024 for the AY 2019-20and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order 37/43

38 WP(MD)No.32923 of 2025 etc., Prayer in WP(MD)No.32999 of 2025:

to issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1072036807(1) dated 09-01-2025 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD)No.33000 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1071005476(1) dated 09-12-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD) No.33001 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1066128710(1) dated 27-06-2024 for the AY 2018-19and quash the same and consequently direct the 4th 2018-19 by the petitioner under Section 119(2)(b) of the Income-tax 38/43

39 WP(MD)No.32923 of 2025 etc., 14/2024 dated 30-10-2024 and pass any such further or other order Prayer in WP(MD) No.33002 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2024-25/1066130207(1) dated 27-06-2024 for the AY 2019-20 and quash the same and consequently direct the 4th 14/2024 dated 30-10-2024 and pass any such further or other order. Prayer in WP(MD) No.33003 of 2025:

To issue a WRIT OF CERTIORARIFIED MANDAMUS calling for records pursuant to the impugned order of the 4th respondent bearing DIN. ITBA/COM/F/17/2025-26/1075672624(1) dated 17-04-2025 for the AY 2020-21and quash the same and consequently direct the 4th 2020-21 by the petitioner under Section 119(2)(b) of the Income-tax 14/2024 dated 30-10-2024 and pass any such further or other order. 39/43

40 WP(MD)No.32923 of 2025 etc., In all cases :

For Petitioners : Mrs.Lakshmi Gopinathan For Respondents : Mr.R.Murali for R1 and R3 Mr.J.Parekhkumar for R2 and R4 COMMON ORDER Heard both sides.

2.The petitioners are primary agricultural cooperative credit societies. They claim exemption under Section 80P of the Income Tax Act, 1961. For sustaining such claim, they have to file their returns which should be accompanied by a statutory auditor's report. In the case on hand, returns were not filed in time. The petitioners would claim that they were not served with the copy of the auditor's report in time and that is how the delay in question had taken place. 3.The learned standing counsel for the department opposed the writ prayers. His contention is that the statutory auditor reports were received by the petitioners well in time and that there were willful default in filing the returns. He called upon this Court to dismiss all these writ petitions.

40/43

41 WP(MD)No.32923 of 2025 etc., 4.Explanation given by the petitioners does not appear to be all that convincing. Be that as it may, the Hon'ble Division Bench in WA(MD)No.2334 of 2025 dated 13.08.2025 had taken an indulgent view and exercised its jurisdiction for the purpose of condoning the delay and for acceptance of returns in accordance with the provisions of the Act and Rules. The very same approach has been adopted by a learned Judge of this Court vide order dated 13.08.2025 in WP(MD)Nos.22108 of 2025 etc., batch.

5.Respectfully adopting the very same approach, I quash the orders impugned in these writ petitions. The delay occasioned in filing the returns stands condoned. These writ petitions are allowed accordingly. No costs. Connected miscellaneous petitions are closed. 21.11.2025 NCC : Yes / No Index : Yes / No Internet : Yes/ No Skm 41/43

42 WP(MD)No.32923 of 2025 etc., To:

1.The Secretary, Union of India, Ministry of Finance, Income Tax Department, North Block, New Delhi - 110 001.

2.The Central Board of Direct Taxes, (CBDT), Rep.by its Chairman, North Block, New Delhi - 110 001.

3.Ministry of Cooperation, Government of India, Rep.by its Secretary, Atal Akshay Ujra Bhawan, CGO Complex, Lodhi Road, New Delhi.

4.The Chief Commissioner of Income Tax, Office of the CCIT, Bibikulam, Madurai - 625 002.

42/43

43 WP(MD)No.32923 of 2025 etc., G.R.SWAMINATHAN,J.

SKM WP(MD)Nos.32923 to 33003 of 2025 21.11.2025 43/43