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HC held assessment proceedings invalid where conducted against non-existent company post-merger. Despite AO's awareness of merger during assessment and in original order, assessment was made against merged entity. Subsequent rectification attempt after three years during pending appeal was rejected. Court distinguished this from cases of inadvertent errors under Section 292B, emphasizing fundamental jurisdictional defect. No evidence of assessee misleading or suppressing merger facts. Use of merged entity's letterhead for correspondence insufficient to validate proceedings. Assessment order nullified following Maruti Suzuki and Mahagun Realtors precedents on jurisdictional invalidity of proceedings against non-existent entities.
HC held assessment proceedings invalid where conducted against non-existent company post-merger. Despite AO's awareness of merger during assessment and in original order, assessment was made against merged entity. Subsequent rectification attempt after three years during pending appeal was rejected. Court distinguished this from cases of inadvertent errors under Section 292B, emphasizing fundamental jurisdictional defect. No evidence of assessee misleading or suppressing merger facts. Use of merged entity's letterhead for correspondence insufficient to validate proceedings. Assessment order nullified following Maruti Suzuki and Mahagun Realtors precedents on jurisdictional invalidity of proceedings against non-existent entities.
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