Vedanta Ltd. v. Dy. CIT (2021) 438 ITR 680 (Mad.)(HC)

S. 148 : Reassessment-Notice-Amalgamation-Notice issued after amalgamation in name of erstwhile company-Similarity in names but Permanent Account Number the same-Bona fide mistake-Correcting the mistake and final assessment order was passed-Order was held to be valid. [S. 147, 292B]

Dismissing the petition the Court held that the petitioner was provided with an opportunity to defend its case in the manner prescribed and the assessment order was passed following the procedure contemplated. There was thus no reason to interfere with the process of reassessment already completed. It would be for the petitioner to redress its grievances, if any, by preferring an appeal, in the manner prescribed under the Act. There was no infirmity or perversity warranting undoing the processes undertaken already, pursuant to the notices issued under section 148 of the Act. On the facts   the notice is intended to be issued to the person to whom it is issued and such person also acknowledged the permanent account number, which was rightly mentioned, and responded to the letters and notices issued by the Department, the name mentioned wrongly is a mistake to be fit in with the provisions of section 292B of the Act. (AY. 2008-09)