THE HON’BLE THE CHIEF JUSTICE SRI APARESH KUMAR SINGH AND THE HON’BLE SRI JUSTICE G.M.MOHIUDDIN WRIT PETITION Nos.33684, 33691, 33708, 33759 and

33794 of 2025

COMMON ORDER:

Learned counsel Sri Ekant Hiranandan, representing learned counsel Sri M.Pranav, appears for the petitioners.

Learned counsel Sri B.Mukherjee, representing Sri N.Bhujanga Rao, learned Deputy Solicitor General of India, appears for Union of India.

Learned counsel Sri Srinarayan Toshniwal, representing Sri N.Praveen Reddy, learned Senior Standing Counsel, appears for Income Tax Department.

2. The Principal Commissioner of Income Tax (Central), Hyderabad (for short ‘PCIT(central)’), passed an order under Section 271DA of the Income Tax Act, 1961 (for short ‘the Act’), on 30.03.2025, granting absolute stay of recovery of the accumulated demand of Rs.428,98,50,568/-, on M/s.Vasavi Group of Cases (for short ‘the assessee’) involving the petitioner companies for various assessment years.

3. The absolute stay was granted on the conditions that the assessee will cooperate during the appeal proceedings without seeking adjournment; the order was valid till the disposal of the first appeal pending with CIT(A) and any non-compliance to the above conditions would render the stay invalid and recovery proceedings would be initiated.

4. It is not in dispute that the assessee was not able to attend on several dates in the appeal proceedings due to personal reasons, which led to vacation of the order of stay by PCIT (central) vide letter dated 21.10.2025 and issuance of impugned demand notice dated 23.10.2025 by the Assistant Commissioner of Income Tax, Central Circle-3(2), Hyderabad.

5. Assessee was treated as assessee in default in respect of the above outstanding demand. Similar notices have been issued in respect of the petitioners in all these matters, which are being decided by the present common order.

6. Being aggrieved by the impugned demand notices, all the petitioners have preferred the present Writ Petitions.

7. Today, at the hearing, learned counsel for the parties are in consensus that the matters can be disposed of in the lines of common order dated 04.11.2025, passed by this Court in Writ Petition No.33425 of 2025 and batch cases, where similar issue was involved between the same parties. 8. Following the same, it is directed that the petitioners should participate in the appeal proceedings diligently without any default or without seeking unnecessary adjournment so that the appeal can be disposed of within the period of limitation. Petitioners are also allowed to make a fresh application for recall of the impugned notices dated 23.10.2025 before the PCIT (Central), by 14^th November, 2025.

9. Within two weeks of such application being filed, the PCIT (Central) shall take a fresh decision thereon.

10. Till such decision is taken by the PCIT (Central), the respondents would not proceed to recover the amount indicated in the impugned notices from the petitioners.

11. However, it is made clear that if the petitioners fail to make such an application within the stipulated time, it would be open for the respondents to proceed for recovery of the demand.

12. With the aforesaid observations, the instant Writ Petitions are disposed of. No costs.

As a sequel, miscellaneous petitions, pending if any, stand closed.

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APARESH KUMAR SINGH, CJ ______________________________________

G.M.MOHIUDDIN, J

10.11.2025 vs