2025 (2) TMI 708

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..... e have granted the Rule in this petition, we are not inclined to stay the assessment proceedings. This is because though the Section 148A (b) notice dated 11 March 2023 was issued in the name of DDB Marketing Services Private Limited, the final order u/s 148A (d) dated 10 April 2023 was issued in the name of the petitioner, into which the earlier company had amalgamated. The impact of citing the .....

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..... e clarify that the reassessment proceedings will abide by the final orders in this petition.
M.S. SONAK & JITENDRA JAIN, JJ. For the Petitioner: Mr Sham V Walve, a/w Abhishek Khandelwal, Bhavik Chheda,. For the Respondent: Mr Akhileshwar Sharma,. PC:- 1. Heard learned counsel for the parties. 2. Rule. 3. Mr Sharma waives service after Rule on behalf of the respondents. 4. This petitio .....

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..... ved with the notice under Section 148 by the jurisdictional Assessing Officer proposing to reopen the assessment. This notice is also challenged in this petition. 8. Although we have granted the Rule in this petition, we are not inclined to stay the assessment proceedings. This is because though the Section 148A (b) notice dated 11 March 2023 was issued in the name of DDB Marketing Services Priva .....

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..... 148A (d) were issued in the name of the non-existent amalgamating company. To that extent, we will have to decide whether the decision in UBER India Systems (P) Ltd. (supra) is distinguishable. 11. For the above reasons, while we decline interim relief, we clarify that the reassessment proceedings will abide by the final orders in this petition. Besides, we grant the parties liberty to apply. 1 .....

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