https://www.taxtmi.com/caselaws?id=783986 After a modified return was filed under s.170A to give effect to an amalgamation scheme, the AO had already completed assessment for the relevant AY by an order dated 26.03.2025, with supporting particulars (including loss and unabsorbed depreciation) having been disclosed in the tax audit material. The dominant issue was whether the AO could thereafter issue fresh notices under ss.143(2) and 142(1) for the same AY to reassess income on the basis of the s.170A modified return. The HC held that a strong prima facie case existed against such fresh initiation and that balance of convenience favoured the assessee; consequently, it granted ad-interim restraint against all steps pursuant to the impugned notices, including passing any assessment order. en-us Tue, 16 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783986 After a modified return was filed under s.170A to give effect to an amalgamation scheme, the AO had already completed assessment for the relevant AY by an order dated 26.03.2025, with supporting particulars (including loss and unabsorbed depreciation) having been disclosed in the tax audit material. The dominant issue was whether the AO could thereafter issue fresh notices under ss.143(2) and 142(1) for the same AY to reassess income on the basis of the s.170A modified return. The HC held that a strong prima facie case existed against such fresh initiation and that balance of convenience favoured the assessee; consequently, it granted ad-interim restraint against all steps pursuant to the impugned notices, including passing any assessment order. Case-Laws Income Tax Tue, 16 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783986