Tribunal held that that it was in the knowledge of the Commissioner that the assessee had merged with Gollops Motor Pvt Ltd  but he still continued with the proceedings. Gollops Motor Pvt Lt  had been filing its return at Ahmedabad from the assessment year 2015-16, i. e., after merger of the assessee with G Gollops Motor Pvt Ltd .  The Commissioner ought to have remitted the record to the Commissioner having jurisdiction over Gollops Motor Pvt Ltd  for taking action under section 263 , if any such ground was available. The notice under section 263 was issued upon a non-existent entity. It was not sustainable. Therefore, no proceeding could be assumed in the legal sense. Consequently, the order passed under section 263 against a non-existent entity was a nullity and void ab initio.( AY.2012-13)