THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE SUDDALA CHALAPATHI RAO WRIT PETITION Nos.19335 & 19336 OF 2025 COMMON ORDER : (per Hon’ble Sri Justice P.Sam Koshy)

Heard Ms.K.Srilatha, learned counsel for the petitioners and Ms. J.Sunitha, learned Senior Standing Counsel for the Income Tax Department for the respondents. Perused the record.

2. These are the two writ petitions which has been filed assailing the notice issued by the respondents under Section 179 of the Income Tax Act 1961 (for short ‘the Act’), dated

02.04.2025.

3. Since the matter involves common question of law and facts, these two matters have been proceeded and decided by way of this common order.

4. The primary contention raised by the petitioner at the first instance was that the petitioner was earlier on 14.07.2022 had issued with notice under Section 179 of the Act for the same assessment year 2017-18 and subsequently, the respondents themselves have dropped the proceedings dated 28.10.2022.

Subsequent to the dropping of proceedings, there does not seem to be any further order passed recalling the dropping of proceedings under Section 179 of the Act as it stood on 14.07.2022. Abruptly, anothe