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    <title>2024 (5) TMI 223 - DELHI HIGH COURT</title>
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    <description>Reassessment proceedings against amalgamating entities were invalid because the notices were issued to companies that had ceased to exist. The only notice addressed to the assessee was also unsustainable, as it proceeded on the mistaken premise that no return had been filed and ignored the return already submitted along with material showing the relevant transaction. The court held that in reassessment the authority must consider available material and form at least a prima facie view with application of mind; mechanical invocation of jurisdiction is impermissible. The notice under section 148A(b) and the order under section 148A(d) were set aside in favour of the assessee.</description>
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      <title>2024 (5) TMI 223 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=752170</link>
      <description>Reassessment proceedings against amalgamating entities were invalid because the notices were issued to companies that had ceased to exist. The only notice addressed to the assessee was also unsustainable, as it proceeded on the mistaken premise that no return had been filed and ignored the return already submitted along with material showing the relevant transaction. The court held that in reassessment the authority must consider available material and form at least a prima facie view with application of mind; mechanical invocation of jurisdiction is impermissible. The notice under section 148A(b) and the order under section 148A(d) were set aside in favour of the assessee.</description>
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