COMMON ORDER:

(per Hon’ble Sri Justice Sujoy Paul)

Sri T.Chaitanya Kumar, learned counsel appears for the petitioner(s), Ms.J.Sunitha, learned Junior Standing Counsel appears for the respondents - Income Tax Department in W.P.No.13904 of 2024, Sri Vijhay K Punna, learned Senior Standing Counsel appears for the respondents - Income Tax Department in W.P.No.13942 of 2024 and Sri B. Mukherjee, learned counsel representing Sri Gadi Praveen Kumar, learned Deputy Solicitor General of India, for the respondents-Central Government, in both the writ petitions.

2. Regard being had to the similarity of the question involved, on the joint request of the parties, the matters are analogously heard and decided by this common order.

3. It is common ground taken by the learned counsel for the petitioner(s) that in furtherance of Finance Act, 2021, re- assessment process stood modified but the respondents have not taken care of it and therefore notices issued under Section 148 of the Income Tax Act, 1961 cannot sustain judicial scrutiny. Since notices are bad in law, the consequential orders are also bad in law.

4. During the course of hearing, learned counsel for the parties agreed that curtains on this