2019 (7) TMI 1580

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.... Arun Kumar, Junior Standing Counsel ORDER The rejection of the petitioner's objections to the Notice issued under Section 148 of the Income Tax Act, is under challenge in the present writ petition. 2. The learned counsel for the petitioner had, predominantly raised a ground stating that the Company was dissolved with effect from 01.04.1999 and apparently the Notice under Section 148 ....

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....hat, they had not filed any income tax returns for the assessment year 2000-01 in view of the demerger with effect from 01.04.1999. The assessment order was passed on 29.03.2005 and subsequently, the High Court had also confirmed the dissolution on 27.06.2006. In view of these developments, the Notice under Section 148, for reopening the assessment of M/s.M.Ct.M.Corporation Pvt. Ltd., for the asse....

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...., while replying to the petitioner's letter dated 05.04.2007, had found it necessary to reopen, based on the notes of accounts on the Balance Sheet as on 31.03.2000. This aspect is disputed by the petitioner, since M/s.M.Ct.M.Corporation Pvt. Ltd., was dissolved with effect from 01.04.1999 itself and they had intimated the respondent of not filing the income tax returns for the assessment year....

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....r may have certain valid grounds to raise in connection with the demerger of the petitioner's Company with effect from 01.04.1999, it would be appropriate for the respondent to reconsider the objections. 8. In view of these disputed facts, I do not intend to go into the reasonings adduced by both the parties, but would rather feel it appropriate that the Assessing Officer re-considers such ....