2024 (6) TMI 1426

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.... Tax<br>THE HON&#39;BLE MR JUSTICE S SUNIL DUTT YADAV FOR THE PETITIONER : SRI. ANNAMALAI S, ADVOCATE FOR THE RESPONDENTS : SRI. THIRUMALESH M., ADVOCATE ORDER Learned counsel Sri. Thirumalesh accepts notice for the respondents. 2. The present petitioner M/s. Rajdisle Private limited bearing PAN No.AAECR5444G is stated to be an entity consequent to the order of amalgamation passed b....

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....019. Accordingly, the present petitioner - company was the new entity after amalgamation. 4. The amalgamated company has filed its returns for the assessment year 2020-21. Copy of which is produced at Annexure-&#39;G&#39;. This factum of amalgamation has been brought to the notice of the revenue by virtue of the letter dated 19.01.2021 duly acknowledged on 28.01.2021. 5. It is to be noticed ....

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....ubstantive illegality and is an order passed without jurisdiction. Same has been followed by this Court in several judgments including in W.P.No.9594/2023 in the case of Coffee Day Resorts (MSM) Pvt. Ltd., Vs. Deputy Commissioner of Income Tax. 7. In light of the above, clearly the notice at Annexure-&#39;A1&#39; as well as notices at Annexures-&#39;A2&#39; and &#39;A3&#39; for the assessment y....