https://www.taxtmi.com/caselaws?id=766108 Delhi HC ruled in favor of the assessee regarding assessment reopening under Section 147 against a non-existent company. The court held that despite the AO being aware of the merger and considering it in the assessment order, the AO erroneously framed the order in the name of a company that had ceased to exist due to merger. The rectification order passed three years later during pending appeal proceedings was not a case of inadvertent error discovery. Relying on SC precedents in Maruti Suzuki and Mahagun Realtors cases, the court determined such mistakes fall outside Section 292B scope and would constitute impermissible amendment of fundamental jurisdictional errors. en-us Thu, 30 Jan 2025 00:00:00 +0530 Tue, 18 Feb 2025 08:10:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766108 Delhi HC ruled in favor of the assessee regarding assessment reopening under Section 147 against a non-existent company. The court held that despite the AO being aware of the merger and considering it in the assessment order, the AO erroneously framed the order in the name of a company that had ceased to exist due to merger. The rectification order passed three years later during pending appeal proceedings was not a case of inadvertent error discovery. Relying on SC precedents in Maruti Suzuki and Mahagun Realtors cases, the court determined such mistakes fall outside Section 292B scope and would constitute impermissible amendment of fundamental jurisdictional errors. Case-Laws Income Tax Thu, 30 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766108