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TMI Blog2022 (5) TMI 56X X X X Extracts X X X X X X X X Extracts X X X X ..... y allowed. Both the impugned notices for the relevant assessment years issued under Section 148 of the Act are hereby ordered to be quashed. - Decided in favour of assessee. - HONOURABLE MR. JUSTICE J.B.PARDIWALA AND HONOURABLE MS. JUSTICE NISHA M. THAKORE MS NUPUR D SHAH FOR THE PETITIONER MR MR BHATT SENIOR COUNSEL WITH MR KARAN SANGHANI, ADVOCATE AND MS MAITHILI D MEHTA FOR THE RESPONDENTS ORDER PER : HONOURABLE MR. JUSTICE J.B.PARDIWALA 1 By this writ application under Article 226 of the Constitution of India, the writ applicant has prayed for the following reliefs: a) The Hon ble Court be pleased to issue a writ of mandamus or any other appropriate writ, order, direction or command in the nature o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... interim relief in terms of para 8(a), (b), (c) and (d) hereinabove; f) Award the cost of this petition. g) Grant such other and further reliefs as this Hon ble Court deems fit. 2 We need not delve much into the facts giving rise to this litigation as this writ application can be allowed on a short legal ground. 3 The subject matter of challenge in the present writ application is to the notice issued under Section 148 of the Income Tax Act, 1961 dated 20th April 2021 for the assessment year 2013-14 calling upon the noticee namely Shivganga Property Holders Private Limited to show cause as to why the assessment for the year 2013-14 should not be reopened under Section 147 of the Act. One another notice has also been issu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 01 April, 2018 being the appointed date as mentioned in the Scheme and the confirmation order Ref: RD (NWR)/233/ (15)/2018/2868 dated 11.09.2018 of the Hon'ble Regional Director, North Western Regional, Ahmedabad, Gujarat. In terms of the said order and final approved scheme our Company being one of the Transferor Company merged with the Transferee Company w.e.f 01st April, 2018 and also shall be stand dissolved without any further acts or deeds. With respect to above, please find attached herewith as under: 1) Copy of Order for Amalgamation. 2) Copy of duly approved Scheme of Amalgamation. Accordingly, kindly note that we will be also making necessary applications for surrender of Permanent Account Number (PAN) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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