TMI Blog2022 (10) TMI 1058X X X X Extracts X X X X X X X X Extracts X X X X ..... , Advocates. Respondent: Mr. Ruchir Bhatia, Senior Standing Counsel for Revenue. JUDGMENT MANMOHAN, J (Oral): 1. Present Writ Petition has been filed challenging the Order passed under Section 148A(d) of the Income Tax Act, 1961 ('the Act') and the Notice issued under Section 148 of the Act, both dated 20th July, 2022 for the Assessment Year ('AY') 2014-15. 2. Learned Counsel for the Peti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r under Section 148A(d) in the name of Sare Marketing Private Limited. He also emphasises that on 9th February, 2016, the Assessing Officer had passed an assessment order with regard to the erstwhile company for the Assessment Year 2013-14, after taking into account the factum of amalgamation of Sare Marketing Private Limited with the petitioner company. 4. He submits that the notice being in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Hon'ble Delhi High Court's order dated 19.09.2014. Therefore, it is on records that the entity M/s Sare Marketing Pvt. Ltd. was not in existence on the date of issue of notices u/s 148A(b) and u/s 148 of the Income-tax Act, 1961. 8. In view of the aforesaid facts and the stand taken by the respondent the impugned order passed under Section 148A(d) of the Income Tax Act, 1961 and the Notice iss ..... X X X X Extracts X X X X X X X X Extracts X X X X
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