TMI Blog2015 (9) TMI 235X X X X Extracts X X X X X X X X Extracts X X X X ..... ently this Court in CIT v. Images Credit and Portfolio Pvt. Ltd (2015 (9) TMI 234 - DELHI HIGH COURT) held that proceedings under Section 153C could not be initiated against an entity that had ceased to exist at the relevant time. Similarly in Spice Enfotainment Ltd. v. CIT (2011 (8) TMI 544 - DELHI HIGH COURT) it was held by this Court that the defect of passing an assessment order in respect of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l For the Respondent : Ms Suruchi Aggarwal, Senior Standing Counsel with Ms Lakshmi Gurung, Junior Standing Counsel ORDER 1. These appeals by the Revenue are directed against the common order dated 28th November, 2014 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA Nos.5307, 5308/Del/2013 and 2356 2357/Del/2014 for the Assessment Years ( AY ) 2005-06, 2006-07, 2003-04 a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Income Tax (Appeals) [CIT (A)]. The CIT (A) also rejected the plea noting that the return of income filed on 18th November 2010, nearly eight months after the notice dated 29th March 2010under Section 153A (1), was in the name of Mayank Traders P Ltd and that no reference was made to its amalgamation with OPPL. The CIT (A) further noted that the Respondent was corresponding with the AO by letter ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d 3rd August 2015 in ITA No. 475/2000 (Spice Enfotainment Ltd. v. CIT) it was held by this Court that the defect of passing an assessment order in respect of an entity that had ceased to exist on the date of such order, could not be treated as a mere procedural defect. The mere fact that the Respondent communicated to the AO, prior to the Assessment order and subsequent notice, in its name without ..... X X X X Extracts X X X X X X X X Extracts X X X X
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