9911796707
TMI Blog2022 (8) TMI 1488X X X X Extracts X X X X X X X X Extracts X X X X ..... cts obtained in the present case clearly disclosing that petitioner company even as on date of issuance of impugned notice dated 27.3.2021 was not in existence by virtue of same having been amalgamated with effect from 1.4.2015 itself or it had ceased to be in existence from the said date and this fact was also being within the knowledge of the jurisdictional ITO by virtue of communications dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er dated 15.2.2022 passed in Special Civil Application No.17039 of 2021, similar orders may be passed in this application also. He places on record the assessment order dated 31.3.2022. 3. Having heard learned counsel appearing for the parties, we notice that in this Special Civil Application, proceedings under Section 147 came to be initiated by issuance of notice under Section 148 on the pu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion No.17039 of 2021, disposed of on 15.2.2022, has held thereunder as follows:- 5. Ms. Shah further invited the attention of this Court to the two letters of even date 23rd July 2021 addressed to the jurisdictional Assessing Officer by the Director of the erstwhile Shivganga Property Holders Private Limited bringing it to his notice that the impugned notice could not have been issued. 6. M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... his fact was also being within the knowledge of the jurisdictional ITO by virtue of communications dated 23.11.2015 and 27.1.2016 forwarded by the petitioner to the said authorities impugned notice cannot be sustained. 5. Hence, we proceed to pass following: ORDER (1) Special Civil Application is ALLOWED. (2) Notice dated 27.3.2021 and show cause notice dated 21.3.2022 as well as c ..... X X X X Extracts X X X X X X X X Extracts X X X X
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