Assessee-bank filed instant writ petition against assessment order passed in name of non-existent entity Oriental Bank of Commerce (OBC) despite prior intimation of merger and PAN cancellation. High Court, on 17-3-2025, proposed imposition of costs of Rs. 1 crore on respondents/revenue for negligent assessment action without independent verification and over-reliance on software systems, and issued notice granting revenue an opportunity to show cause why such costs should not be imposed. Revenue filed an affidavit stating that systems were being continuously updated to address such issues and tendered unconditional apology seeking relief from proposed costs.It was noted that revenue department was taking corrective proactive steps for resolution of issues which were raised in this petition pertaining to initiation of proceedings on dead persons/amalgamated companies or business and inactive or multiple PANs in software system of department.  Court held  since revenue department was blindly following information made available by software system and taking action without verifying veracity of same, present petition was a classic example where little verification or application of mind by Jurisdictional Assessing Officer would not have resulted into this litigation and it could have been avoided by not taking any action more particularly, when there was a merger of one National Bank with petitioner bank. Since action was taken by department against Jurisdictional Assessing Officer on administrative side, Court did not want to further prejudice such departmental action by observing in any manner.  Petition was therefore to be disposed of with a cost of Rs. 10,000 to be paid by revenue with Gujarat State Legal Service Authority as a token cost instead of Rs. 1 crore proposed earlier.