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of <h1>Appellate tribunal rules no liability on amalgamating company in s. 104 proceedings</h1> <h3>INCOME TAX OFFICER. Versus TV. SUNDARAM IYENGAR & SONS.</h3> INCOME TAX OFFICER. Versus TV. SUNDARAM IYENGAR & SONS. - TTJ 013, 509, 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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