2024 (7) TMI 1690

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....s and Solvent Private Limited changed its name to Pon Pure Chem Private Limited on 26.06.2008 and eventually from Pon Pure Chem Private Limited to Pon Pure Chemical India Private Limited on 13.03.2015. As regards assessment year 2015-2016, an assessment order was issued in the name of the resulting company on 20.12.2017. Thereafter, a notice dated 19.03.2022 under Section 148A(b) was issued to the transferor company under the scheme of amalgamation. The resulting company replied thereto on 22.03.2022 and stated that PAN AADCP3173B, which had been allotted to the transferor company, was surrendered on 01.08.2008. Thereafter, show cause notice dated 28.02.2023 was issued to the transferor company. By reply dated 08.03.2023, it was stated that....

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....d the judgments in Maruti Suzuki and Mahagun Realtors and concluded that the decision in Mahagun Realtors turned on the fact that the transferor company had participated in proceedings without bringing to the notice of the Income Tax authorities the amalgamation and even filed a return of income. By distinguishing the said judgment, he pointed out that the Court applied the ratio of Maruti Suzuki. On the merits of the case, learned counsel submits that the petitioner pointed out that account No.531470742 was not maintained with the Punjab National Bank by the transferor company. He also pointed out that the Punjab National Bank confirmed this position by communication dated 06.03.2023. 3. In response to these contentions, Mr.V.Mahalingam, ....