During the year, a company called Synovate was merged with assessee company, IPSOS, pursuant to an order of the High Court. The fact of amalgamation was first brought to the notice of the TPO vide a letter dated 9-1-2014. Despite this, Draft Assessment Order under section 144C (1) was passed in the name of Synovate. Apart from this, Assessing Officer himself, by his letter dated 2-6-2014, addressed a letter to Synovate (since merged with IPSOS). This also showed that the Assessing Officer, at least as on 2-6-2014, was aware of the aforesaid merger. Despite all this, the Assessing Officer passed the final assessment order only in the name of the amalgamating company, Synovate, which had ceased to exist. Tribunal quashed the assessment order. On appeal, the Court held that since the final assessment order was passed in the name of a non-existent entity, it could not be sustained and was quashed. (AY. 2010-11)
PCIT v. IPSOS Research (P.) Ltd. (2026) 308 Taxman 492 (Bom.)(HC)
S. 143(3): Assessment-Merger-Amalgamation-Final assessment order was passed in the name of a non-existent entity; the order was quashed. [S. 144C, 260A]
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