2022 (10) TMI 1287

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....M: This assessee's appeal for A.Y. 2017-18 arises against the National Faceless Assessment Centre, Delhi's assessment dated 30.01.2022, framed in furtherance to CIT(DRP-3), Mumbai-2's directions dated 07.12.2021, in TIN order no. ITBA/TPO/F/92CA3/2020-21/1029839432(1), involving proceedings under section 92CA(3) of the Income Tax Act(in short "the Act"). Heard both the parties. Case file peruse....

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....rein M/s. E-Infochips Ltd., had undergone an amalgamation as per honourable Gujarat high court's approved scheme dated 29.03.2016 w.e.f. 01.04.2015 involving M/s. Small Guard Systems and M/s. nGin Technologies Pvt. Ltd. That being the case, we hold that the foregoing extraordinary event of amalgamation renders M/s. E-Infochips Ltd., as not a valid comparable as already held in tribunals' co-ordina....