Petition challenging reassessment under s.147/148 (explanation 1) dismissed; merger effective only on sanction 13.11.2020, taxpayer distinct.

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....The HC dismissed the petition challenging reopening under s.147/148, holding the reopening valid because the scheme of merger became effective only upon NCLT sanction on 13.11.2020; until then the petitioner remained a distinct legal entity with an active PAN and conducted financial transactions in AY 2020-21. The CBDT Risk Management Strategy report identified transactions totaling Rs. 11,64,12,993 which, under explanation 1 to s.148, escaped assessment. The Court found the transferee's return was accepted as nil after scrutiny, but the petitioner continued business during the merger process; consequently the petitioner's contention of cessation from 01.04.2018 was rejected and the writ petition was dismissed.....