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2022 (7) TMI 337 - HC - Income TaxReopening of assessment u/s 147 - Notice issued against a non-existent company - Scheme of amalgamation Conceived - HELD THAT:- Petitioner states that Income Tax Officer Ward No. 19(1), Delhi has issued a letter dated 27th May, 2022 to the Petitioner stating that the notices issued under Section 148 of the Act between 01st April, 2021 to 30th June, 2021 have been held by the Supreme Court in Union of India & Ors. vs Ashish Agarwal, [2022 (5) TMI 240 - SUPREME COURT] to be show cause notices under Section 148A(b) of the Act and initiated fresh reassessment proceedings against the amalgamated company. In the opinion of this Court, the Petitioner should take all its objections in its reply to be filed before the Assessing Officer in the proceedings under Section 148A of the Act. In the event, the time for filing the reply has expired, the Petitioner is given liberty to raise additional grounds by filing a supplementary reply within a week. In case, the Petitioner is aggrieved by the decision of the Assessing Officer, it shall be open to the Petitioner to challenge the same in accordance with law.
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