Assessment of holding company with notice to subsidiary is invalid

Brief of the Case Bombay High Court held In the case of Techpac Holdings Ltd. vs. DCIT that it is an admitted position that notices under sections 148, 142(1) and 143(2), never served on the Petitioner. The Revenue seeks to justify service of these notices by contending that they have served the said notices on the last known address of the Petitioner which was the address of Ingram Micro India [earlier known as Tech Pacific India], the downstream company of the Petitioner. We fail to see how the notices being served on Ingram Micro India would amount to service on the Petitioner. This is mor...