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    <title>2012 (6) TMI 87 - DELHI HIGH COURT</title>
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    <description>Reassessment notices could not be sustained where the original assessments had already considered the amalgamation and the consolidated accounts. The notices proceeded on the assumption that no amalgamation had occurred during the relevant years, but that foundation was inconsistent with the assessment record. The critical issue of the amalgamation&#039;s effective date had also been finally resolved in earlier proceedings, with the Tribunal finding it effective from 1 July 1982 and the Revenue not pursuing further reference. On that finality, the factual basis for reassessment failed and the notices were quashed in favour of the assessee.</description>
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      <title>2012 (6) TMI 87 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=213767</link>
      <description>Reassessment notices could not be sustained where the original assessments had already considered the amalgamation and the consolidated accounts. The notices proceeded on the assumption that no amalgamation had occurred during the relevant years, but that foundation was inconsistent with the assessment record. The critical issue of the amalgamation&#039;s effective date had also been finally resolved in earlier proceedings, with the Tribunal finding it effective from 1 July 1982 and the Revenue not pursuing further reference. On that finality, the factual basis for reassessment failed and the notices were quashed in favour of the assessee.</description>
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      <pubDate>Tue, 15 May 2012 00:00:00 +0530</pubDate>
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