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The appellate tribunal dismissed the departmental appeal regarding the initiation of s. 104 proceedings against the successor amalgamated company, T.V. Sundaram Iyengar & Sons (P) Ltd., ruling that there was no liability on the part of the amalgamating company, Sundaram Motors (P) Ltd. The tribunal also rejected the argument that s. 104 proceedings could be considered as assessment proceedings under s.170 of the IT Act, 1961.
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