Hornbill Infrastructure Services Pvt. Ltd. and connected petitioners v. Assistant Commissioner of Income Tax, Central Circle 4, Thane & Ors.

1. FACTS OF THE CASE

The petitioners sought correction of the order dated 6 August 2024 through a praecipe for speaking to the minutes. The common record covers Hornbill Infrastructure Services in WP 461/2024; Percy Logistics in WPs 509 and 4191/2024; Coppersmith Energies and Project in WPs 4187 and 4190/2024; and Ashni Logistics in WPs 4188 and 4189/2024.

Source: PDF pp.1–2, captions and paragraph 1

2. DISCUSSION BY THE COURT

The matters were taken on board upon mentioning although not listed. The Court directed a specific addition after paragraph 7 of the earlier order, recording that Central Charges status appeared undisputed.

Source: PDF p.2, paragraphs 1–2

3. JUDICIAL DECISION

Paragraph 7A was to be inserted: “It also appears to be not in dispute that the petitioner’s case pertains to Central Charges.” The earlier order was to be corrected accordingly and supplied to the parties.

Source: PDF p.2, paragraphs 2–3

4. OUTCOME

This 10 September 2024 common order corrects the record of the 6 August order. It contains no fresh adjudication of reassessment validity, tax liability or final disposal of the underlying writ petitions.

Source: PDF p.2, paragraphs 1–3

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Read the two orders together

The new paragraph qualifies the factual context of the earlier order by recording Central Charges status. Its significance for the underlying reasoning must be assessed with the 6 August order; this two-page correction does not reproduce that reasoning or its operative relief.

Source: PDF p.2, paragraphs 1–3

An undisputed fact is not a statutory ruling

Paragraph 7A says the case pertains to Central Charges. It does not independently decide the reach of a faceless scheme or establish that a notice is valid or invalid. Converting the correction into a substantive jurisdictional holding would go beyond the text.

Source: PDF p.2, inserted paragraph 7A

One common order retains seven proceedings

All seven writ numbers are printed in every copy of this common order. The separate source-file identifiers are retained as provenance aliases, while each docket and petitioner remains identified in the canonical note. The 10 September correction remains distinct from the earlier 6 August order.

Source: PDF pp.1–2, captions