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TMI Blog2025 (4) TMI 1456X X X X Extracts X X X X X X X X Extracts X X X X ..... ing on behalf of the Petitioner and learned Senior Standing Counsel Mr. Varun K. Patel for the Respondents. 2. Rule returnable forthwith. Learned Senior Standing Counsel Mr. Varun Patel waives service of the notice of the rule on behalf of the Respondents. With the consent of the learned advocates for the respective parties, the matter is taken up for hearing, as the issue involved is very short. 3. The brief facts of the case are as follows: 3.1 The Petitioner is a Limited Liability Partnership (LLP). One Kauvery Trexim Private Limited (the Assessee) stood amalgamated with Vital Connections Private Limited pursuant to an order dated 15.12.2017 passed by the learned National Company Law Tribunal (NCLT). Subsequently, Vital Connections Pr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of the objections raised against the reopening of assessment. On the same date, i.e., 29.03.2022, the Petitioner also submitted detailed written submissions on the merits of the case and further requested for a hearing through video conferencing. 3.6 However, without disposing of the objections or granting a hearing, the Respondent proceeded to pass the assessment order dated 30.03.2022 under Section 147 read with Section 144B of the Act, determining the total income of the Petitioner at 16,14,60,400/-. Consequently, a substantial demand of Rs. 8,28,41,280/- was raised against the Petitioner for the Assessment Year 2015-16. 3.7 Aggrieved by the impugned Assessment Order and the demand notice dated 30.03.2022, the Petitioner has filed th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... othing on record to show that the Petitioner had intimated the merger approval order of the learned NCLT, Ahmedabad to the concerned Jurisdictional Assessing Officer, prior to the issuance of notice under Section 148 of the Act. Accordingly, Mr. Patel submitted that the present petition deserves to be rejected on such ground alone. 6. From the perusal of the records, it will be seen that in response to the notice cum draft Assessment Order dated 28.03.2022 under Section 147 read with Section 144B of the Act, addressed to the Assessee in question namely Kauvery Trexim Pvt. Ltd., the Petitioner had responded on 29.03.2022 (uploaded on the same day), stating the factum of amalgamation and specifically uploading the certified copy of the Schem ..... X X X X Extracts X X X X X X X X Extracts X X X X
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