Amalgamation liability: supplies between merging companies included in turnover, creating tax obligations despite retrospective orders.

Where a merger or amalgamation order is to take effect from an earlier date, any supplies or receipts between the companies during the period from that operative date until the date of the order are to be included in each company's turnover and give rise to tax liability. For GST purposes the companies remain treated as distinct entities for that interim period and their registration certificates are cancelled with effect from the date of the order.

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