JUDGMENT

(Prayer: Writ Appeals filed under Clause 15 of The Letters Patent against the common order dated 03.08.2021 passed in WP Nos. 33432 and 33431 of 2017 respectively on the file of this Court.)

Common Judgment

R. Mahadevan, J.

1. Both these intra-court appeals are filed as against a common order dated 03.08.2021 passed by the learned Judge in WP Nos.33431 and 33432 of 2017.

2. The appellants have preferred the aforesaid writ petitions for issuance of a Writ of Certiorarified Mandamus, calling for the records of the first respondent contained in its order bearing No.TN/CN51/2015-16/34 & 35/IT dated 06.12.2017 and to quash the same as arbitrary, unjust and illegal and to consequently direct the first respondent to reconsider the applications filed by the appellants bearing No.TN/CN-51/2015-16/34 & 35/IT and pass a fresh order under section 245D(4) of the INCOME TAX ACT , 1961, after affording sufficient opportunities of being heard to the appellants in accordance with law.

3. For the purpose of disposal of these appeals, it is essential to look into the common averments made in the affidavits filed in support of the writ petitions and they are elucidated hereunder, in brief.

4.1. The