https://www.taxtmi.com/caselaws?id=761664 The HC of Calcutta dismissed the revenue's appeal under Section 260A of the Income Tax Act, 1961, affirming the ITAT's decision. The Court found that the AO was aware of the company's amalgamation before initiating proceedings under Section 147, rendering the revenue's claim factually incorrect. The Court emphasized that defects affecting jurisdiction, such as issuing notices to non-existing entities, cannot be cured by subsequent actions. The Court distinguished the case from PCIT Vs. Mahagun Realtors Pvt. Ltd., noting the AO's prior knowledge of the amalgamation. Consequently, the substantial questions of law were resolved against the revenue. en-us Fri, 08 Nov 2024 00:00:00 +0530 Wed, 13 Nov 2024 17:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761664 The HC of Calcutta dismissed the revenue's appeal under Section 260A of the Income Tax Act, 1961, affirming the ITAT's decision. The Court found that the AO was aware of the company's amalgamation before initiating proceedings under Section 147, rendering the revenue's claim factually incorrect. The Court emphasized that defects affecting jurisdiction, such as issuing notices to non-existing entities, cannot be cured by subsequent actions. The Court distinguished the case from PCIT Vs. Mahagun Realtors Pvt. Ltd., noting the AO's prior knowledge of the amalgamation. Consequently, the substantial questions of law were resolved against the revenue. Case-Laws Income Tax Fri, 08 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761664