The ITAT held that the assessment order passed under section...

The ITAT held that the assessment order passed under section 143(3) in the name of the transferee bank was invalid as no notice under section 143(2) was issued to it post-amalgamation. Section 292BB does not validate the order since no notice emanated from the department to the transferee bank, consistent with Supreme Court precedent. The merger scheme allowed continuation of pending proceedings of the transferor banks but was silent on proceedings initiated after the scheme's effective date. Since the assessment for AY 2019-20 was initiated after the scheme came into force, provisions relating to continuation of pending proceedings were inapplicable. Consequently, the assessment order framed against the transferee bank without proper jurisdiction was quashed, and the assessee's cross-objections were allowed.

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