TMI Blog2019 (2) TMI 1329X X X X Extracts X X X X X X X X Extracts X X X X ..... he purpose of assessment of tax - HELD THAT:- Having regard to the submissions advanced by the learned counsel for the petitioner, Issue Notice returnable on 28th January, 2019. By way of ad-interim relief, the respondent is restrained from proceeding further pursuant to the impugned notice dated 23.3.2018 issued to N.G. Patel Polytechnic for assessment year 2011-12 (Annexure-D to the petition). T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... wherein the court has held that mere allotment of PAN under section 139A of the Income Tax Act, 1961 would not make the allottee necessarily a separate entity for the purpose of assessment of tax. It was pointed out that this judgment is rendered in the context of N.G. Patel Polytechnic, one of the colleges run by the petitioner trust. It was submitted that despite the aforesaid position, for ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 2011-12 having been submitted, the Assessing Officer is adamant and insists upon a return of income being filed in the name of N.G. Patel Polytechnic. It was pointed out that the return of income filed for the year under consideration of the petitioner has already been submitted to the Assessing Officer. 2. It was further pointed out that pursuant to the impugned notice, the petitioner had di ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Officer has refused to furnish the reasons recorded on the ground that the return of income has not been filed by N.G. Patel Polytechnic. It was submitted that merely because a separate PAN has been allotted to N.G. Patel Polytechnic, it does not make it a separate entity for the purpose of assessment of tax as held by this court in the above cited decision dated 11.9.2017. It was submitted that d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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