DCM Shriam Ltd. v. ACIT (2022) 218 DTR 217 / 139 taxmann.com 405/(2023) 334 CTR 811 (Delhi)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation-Appeal pending before DRP-Notice of reassessment is bad in law. [S. 148, Art. 226]

Assessing Officer issued notice under section 148A(b) in name of company, which stood amalgamated with petitioner-company. The petitioner informed the Revenue about the Amalgamation Assessing Officer issued reopening notice in name of petitioner-company with PAN of company, B. On writ allowing the petition the court held that since assessment of petitioner-company for relevant assessment year was pending adjudication before DRP, notice of reassessment is bad in law. (AY. 2018-19)