2021 (9) TMI 121

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....vi Kiran, CIT-DR ORDER S.S. Godara, Member (J) 1. This assessee's appeal for AY. 2014-15 arises against the DCIT, Central Circle-2(3), Hyderabad's assessment dt. 25-10-2018 framed in furtherance to the Dispute Resolution Panel-1 'DRP', Bengaluru's directions dt. 24-09-2018 in F. No. 58/DRP-1/BNG/2018-19, involving proceedings u/s. 143(3) r.w.s. 144C(13) of the Income T....

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....ice(s) dt. 28-08-2015 and 01-09-2015; respectively. The former entity, M/s. Vivimed Labs (Alathur) Pvt. Ltd. thereafter stood amalgamated as M/s. Vivimed Labs Ltd. on 01-12-2015 w.e.f. 01-04-2014. The Assessing Officer thereafter made Section 92CA reference in the present appellant's name followed by the Transfer Pricing Officer's TPO's Section 92CA(3)'s order dt. 30-10-2017, Asses....

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....on that not only the learned lower authorities have mentioned names of both the entities herein i.e. M/s. Vivimed Labs Ltd. as well as M/s. Vivimed Labs (Alathur) Pvt. Ltd. but also they have quoted the PAN of the latter entity (supra) which sufficiently ensures compliance of Section 170 of the Act. Learned departmental representative next sought to pin point the fact that the lower authorities ha....

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....lordships in paras 17(i) as well as (vii) thereof which stood rejected in the hon'ble apex court. We further note that their lordships have considered all these issues in the foregoing detailed judgment whilst concluding that such an assessment does not satisfy the legal requirement involving a duly existent entity. 8. Learned counsel lastly contended that the lower authorities could not be....