City Corporation Ltd. v. ACIT [2025] 171 taxmann.com 301 / (2026) 488 ITR 12 (Bom)(HC)

S. 148: Reassessment-Notice-Amalgamation of companies-Merger-Notice issued on non-existent entity-Notice and consequential orders were quashed. [S. 2(31), Art. 226]

 In terms of NCLT’s order, there was merger of AFTPL into assessee-company CCL with effect from 1-4-2018. The assessee informed the revenue about the merger. However, on 31-3-2023, a reassessment notice was issued only in the name of AFTPL. On writ, the Court held that since notices were issued to a non-existing company or entity despite the revenue’s knowledge of its non-existence, the notice and consequential orders were quashed.   (AY. 2013-14, 2014-15, 2016-17 to 2019-20) 

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