ASIANET STAR COMMUNICATIONS PRIVATE LIMITED Vs. ASSISTANT COMMISSIONER OF INCOME TAX, NON-CORPORATE, CIRCLE-20(1)

JUDGEMENT

(1.) These three Writ Petitions challenge orders rejecting objections filed by the assessee in regard to assumption of jurisdiction by the Assessing Officer for re- assessment under Sec. 147 of the Income Tax Act, 1961 (in short 'Act').

(2.) The Petitioner is a company engaged in the business of production, procurement and broadcasting of movies and programmes over satellite channels. Asianet Communication Limited (petitioner in W.P.No. 25336 of 2018 ) merged with Vijay Television Private Limited (petitioner in W.P.Nos.25328 & 25331 of 2018) vide order of the Mumbai Bench, National Company Law Tribunal dtd. 30/7/2018 in CP(CCA) 9/230-232/NCLT/MB/MAH/2018, approved by the Ministry of Information and Broadcasting on 17/12/2018. Thereafter, the name, Vijay Television Private Limited, stood changed to Asianet Star Communications Private Limited w.e.f. 7/1/2018. The petitioners sought amendment of cause title and the miscellaneous petitions were ordered on 20/3/2019. Common submissions in regard to the three matters have been advanced by both sides and thus a single order is passed in regard to all three Writ Petitions.

(3.) I first take up W.P.No.25328 of 2018 pertaining to assessment year 2011- 12. The facts relevant to appreciate and adjudicate upon the lis before me are as follows: