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2020 Supreme(SC) 354

UDAY UMESH LALIT, VINEET SARAN
Vodafone Idea Ltd. (Earlier Known As Vodafone Mobile Services Limited) – Appellant
Versus
Assistant Commissioner of Income Tax Circle 26 (2) – Respondent


Advocates Appeared:
For the Petitioner(s):B. Vijayalakshmi Menon, Advocate
For the Respondent(s):Zoheb Hussain, Anil Katiyar, Advocates

JUDGMENT :

UDAY UMESH LALIT, J.

1. Leave granted.

2. This appeal arises out of the final judgment and order dated 14.12.2018 passed by the High Court(High Court of Delhi at New Delhi) in Writ Petition (Civil) No.2730 of 2018 preferred by the appellant herein.

3. The facts leading to the filing of this appeal, in brief, are as under:-

[A] The appellant-Vodafone Idea Ltd. (earlier known as Vodafone Mobile Services Ltd or VMSL for short) is engaged in providing telecommunication services in different circles.

    (a) By amalgamation which came into effect on 01.04.2011, four group entities: Vodafone Cellular Ltd., Vodafone Digilink Ltd., Vodafone East Ltd. and Vodafone South Ltd. got merged in VMSL.

    (b) By second scheme of amalgamation, two other group entities: Vodafone Spacetel Ltd. and Vodafone West Ltd. got merged in VMSL w.e.f. 01.04.2012.

    (c) While the proceedings in the instant case were pending, by scheme of arrangement(Formulated by the Order dated 19.1.2018 passed by National Company Law Tribunal, Mumbai and order dated 11.1.2018 by National Company Law Tribunal, Ahmedabad.) between


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