Allowing the petition the Court held that intimation regarding the amalgamation was given in reply to the notice under section 142 in the month of March, 2018. It was the very same officer who after three years of such amalgamation had issued notice in the name of that company, which no longer existed on March 30, 2021 for the assessment year 2016-17. The notice of reassessment was not valid. (AY.2016-17)
Kunvarji Fincorp Pvt. Ltd. v. Dy. CIT (NO. 1) (2023)455 ITR 409 / 293 Taxman 183 (Guj)(HC)
S. 148 : Reassessment-Notice-Amalgamation-Intimation was given to Income-Tax Authorities-Notice in the name of company which had ceased to exist-Not valid. [S. 142(1), 147, Art. 226]