Assessee-company (transferor company) stood merged with another company (transferee company) with effect from 1-4-2012 Assessing Officer issued on assessee-company a notice under section 148 on 31-3-2021 and passed assessment orders dated 31-3-2022 for assessment years 2013-14 and 2016-17. On writ the Court held that it was incumbent on part of transferee company to have included tax liability of assessee-company in view of merger with effect from 1-4-2012 and if this was not done, it was for Assessing Officer to proceed against transferee company and not against assessee-company. Accordingly the Assessment Orders passed against assessee is quashed and set aside. (AY. 2013-14, 2016-17)
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