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The ITAT held that reopening assessment against a deceased person, a non-existing company converted into LLP, is invalid. The company's status as "dissolved" on MCA data means it lost existence. As per sec 2(31), it cannot be assessed. The reassessment u/s 147/148 by AO is without jurisdiction and set aside. Notice u/s 147 and order u/s 144 r.w.s. 147 are quashed. Decision favors assessee.
The ITAT held that reopening assessment against a deceased person, a non-existing company converted into LLP, is invalid. The company's status as "dissolved" on MCA data means it lost existence. As per sec 2(31), it cannot be assessed. The reassessment u/s 147/148 by AO is without jurisdiction and set aside. Notice u/s 147 and order u/s 144 r.w.s. 147 are quashed. Decision favors assessee.
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