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    <title>2024 (6) TMI 332 - ITAT SURAT</title>
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    <description>ITAT Surat held that reassessment proceedings under sections 147/148 against a dissolved company were invalid. The company had converted to LLP and lost its legal existence, as confirmed by MCA records showing dissolved status. The tribunal ruled that notices for reopening assessment against a non-existing entity are invalid, and a dissolved company cannot be treated as a &quot;person&quot; under section 2(31) of the Act. The reassessment order under section 147 was quashed as being without jurisdiction, and the consequential order under section 144 read with section 147 was set aside. Decision favored the assessee.</description>
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    <pubDate>Thu, 06 Jun 2024 00:00:00 +0530</pubDate>
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      <title>2024 (6) TMI 332 - ITAT SURAT</title>
      <link>https://www.taxtmi.com/caselaws?id=753725</link>
      <description>ITAT Surat held that reassessment proceedings under sections 147/148 against a dissolved company were invalid. The company had converted to LLP and lost its legal existence, as confirmed by MCA records showing dissolved status. The tribunal ruled that notices for reopening assessment against a non-existing entity are invalid, and a dissolved company cannot be treated as a &quot;person&quot; under section 2(31) of the Act. The reassessment order under section 147 was quashed as being without jurisdiction, and the consequential order under section 144 read with section 147 was set aside. Decision favored the assessee.</description>
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      <pubDate>Thu, 06 Jun 2024 00:00:00 +0530</pubDate>
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