TMI Blog2017 (12) TMI 1648X X X X Extracts X X X X X X X X Extracts X X X X ..... merged or amalgamated entity, i.e., Adhunik Technology Pvt. Ltd. - Held that:- The rationale for holding that even Section 292B is in applicable in all these cases consistently was that once the corporate entity is merged with another, i.e., transferee corporation or entity, the assessment had to be completed in the latter's hands. In the present case, the revenue despite being intimated did not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 01.11.2004 under Section 115JB of the Income-tax Act, 1961. The original assessment was completed but the matter was remitted on two occasions. In the third round, in reply to notice, the assessee had indicated that it underwent an entity change inasmuch as merger and amalgamation had been approved by the Court vide order dated 10.10.2013 w.e.f. 01.04.2012. Apparently, the AO took note of this ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... care to mention the name of the merged or amalgamated entity, i.e., Adhunik Technology Pvt. Ltd. 3. In the opinion of the Court, the settled position indicated arising from the string of judgment, i.e., Spice Entertainment (supra) onward still CIT v. Vivid Marketing Services (P) Ltd. [IT Appeal No. 273 of 2009], is in no way distinguishable. The rationale for holding that even Section 292B is i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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