The Biodiversity Conservation Society of Telangana (BIOSOT), a statutory society formed pursuant to Supreme Court directions in the T.N. Godavarman case and chaired by the Chief Secretary of Telangana, filed writ petitions under Article 226 challenging a notice and bank account attachment issued by the Income Tax Department under Section 226(3) of the Income Tax Act, 1961. BIOSOT argued that it is a State instrumentality under Article 12 of the Constitution, discharges sovereign environmental and biodiversity conservation functions, and is therefore constitutionally immune from Union taxation under Article 289(1), making the Income Tax Act wholly inapplicable to it. The Income Tax Department countered that the TDS deduction under Section 194C for assessment year 2019-20 was valid and that BIOSOT's constitutional character does not preclude it from entering contractual arrangements attracting TDS provisions. The judgment text provided captures the rival contentions of both parties but does not include the final operative order or holding of the court, as the text appears to be incomplete.