https://www.taxtmi.com/caselaws?id=751311 Revision under s.263 issued in the name of an amalgamated (non-existent) transferor company was held maintainable because the cause title itself recorded the change of name/amalgamation, and amalgamation transfers rights and liabilities to the successor such that issuance in the erstwhile name did not render the proceedings without jurisdiction or a nullity; the challenge to jurisdiction was rejected. On merits, the assessment order was held "erroneous and prejudicial to the interests of the Revenue" since the AO neither called for nor verified details regarding disallowance under s.40(a)(i) for alleged non-deduction of TDS on non-resident payments, and failed to examine disallowance under s.14A r.w. Rule 8D despite exempt income; the s.263 order setting aside assessment and directing fresh assessment was upheld and the appeal was dismissed. en-us Wed, 03 Apr 2024 00:00:00 +0530 Mon, 05 Jan 2026 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751311 Revision under s.263 issued in the name of an amalgamated (non-existent) transferor company was held maintainable because the cause title itself recorded the change of name/amalgamation, and amalgamation transfers rights and liabilities to the successor such that issuance in the erstwhile name did not render the proceedings without jurisdiction or a nullity; the challenge to jurisdiction was rejected. On merits, the assessment order was held "erroneous and prejudicial to the interests of the Revenue" since the AO neither called for nor verified details regarding disallowance under s.40(a)(i) for alleged non-deduction of TDS on non-resident payments, and failed to examine disallowance under s.14A r.w. Rule 8D despite exempt income; the s.263 order setting aside assessment and directing fresh assessment was upheld and the appeal was dismissed. Case-Laws Income Tax Wed, 03 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751311