9911796707
TMI Blog2020 (12) TMI 98X X X X Extracts X X X X X X X X Extracts X X X X ..... of appeal No.1 raised by the assessee is thus allowed. - ITA No.2567/Del/2017 - - - Dated:- 9-9-2020 - Ms. Sushma Chowla, VP And Sh. Anil Chaturvedi, AM For the Appellant : Sh. Somil Agarwal Adv. For the Respondent : Sh. Sanjay Goyal, DR ORDER PER SUSHMA CHOWLA, VP The present appeal is filed by the assessee against order of CIT(A), Karnal relating to assessment years 2010-11 against the order passed under section 153A r.w.s 143(3) of the Income-tax Act, 1961 (in short the Act ). 2. The issue raised vide Ground No.1 is the jurisdictional issue and we proceed to address the same before adjudication of other issues raised on merits. Ground of appeal raised by the assessee is as under:- . That having rega ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... le High Court. The assessee claimed it as the assessee did not exist on the date of service of notice, the assessment was not valid. The CIT(A) rejected the plea of the assessee on the ground that it has not informed the Income tax Department regarding its non-existence within reasonable time. He also decided the issue on merits against the assessee. The assessee is in appeal before us, both on the preliminary issue and also issue raised on merits. 5. The Ld.AR for the assessee pointed out that search of M/s. SRS Group had been carried out on 09.05.2012. He further pointed out that notice u/s 153C of the Act was issued on 10.11.2014. Plea in this regard was that the assessee company had merged with M/s. Akriti w.e.f. 01.04.2012 as per th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s. SRS Group on 09.05.2012, notice u/s 153C of the Act was issued to the assessee for Assessment Year 2010-11. The Assessing Officer had issued notice dated 05.12.2014 u/s 143(2) of the Act alongwith letter dated 05.12.2014 relating to Assessment Years 2007-08 to 2013-14. In this letter, the assessee was asked to furnish the return of income for the past six years alongwith other details. Copy of the said notice and the letter are placed at pages 51 to 55 of the Paperbook. The assessee filed its reply and participated in the assessment proceedings. Simultaneously, assessment proceedings were also carried out for Assessment Year 2013-14. Copy of the order for Assessment Year 2013-14 is also placed on record which is dated 20.03.2015. I ..... X X X X Extracts X X X X X X X X Extracts X X X X
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