Assessee, STIPL filed its return for the relevant assessment year. With effect from 1-4-2008, STIPL merged with the petitioner, transferee company pursuant to a scheme of amalgamation. Said fact was brought to the attention of Assessing Officer. Assessing Officer, however, passed an assessment order in the name of assessee; the Tribunal set aside said order holding that since the assessee company was not in existence at time of passing of said order, the same was a nullity in the eyes of law.High Court, vide order dated 27-3-2025, upheld the Tribunal’s order. High Court, further clarified that its order would not preclude revenue from initiating fresh proceedings against the transferee company.Thereafter, Assessing Officer issued a notice under section 143(2) to the petitioner-company, claiming that income was proposed to be assessed in the petitioner’s hands in ”compliance” with the order of the High Court. On writ, the court held that High Court merely clarified, and there was no ‘direction’ in the said order so as to attract the provisions of section 153(6). Since the order of the High Court did not contain any ‘finding’ or ‘direction’ as contemplated by the provisions of section 153(6), no order of assessment could be passed for the relevant assessment year in view of the bar of limitation in section 153(1). (AY. 2007-08)