https://www.taxtmi.com/caselaws?id=775234 ITAT Delhi held that Revenue cannot assume jurisdiction to issue notice u/s 153A in the name of a non-existing entity without providing hearing opportunity. The assessee company had merged with another company prior to assessment proceedings. The tribunal noted that lower authorities acknowledged this fact, which Revenue could not dispute. Relying on PCIT vs. Maruti Suzuki (SC), ITAT concluded the assessment was unsustainable in law as it was framed against a non-existent entity. The assessment order was quashed and set aside, with the assessee's appeal being allowed. The case establishes that valid legal entity existence is fundamental prerequisite for tax assessment proceedings. en-us Fri, 18 Jul 2025 00:00:00 +0530 Tue, 22 Jul 2025 08:25:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775234 ITAT Delhi held that Revenue cannot assume jurisdiction to issue notice u/s 153A in the name of a non-existing entity without providing hearing opportunity. The assessee company had merged with another company prior to assessment proceedings. The tribunal noted that lower authorities acknowledged this fact, which Revenue could not dispute. Relying on PCIT vs. Maruti Suzuki (SC), ITAT concluded the assessment was unsustainable in law as it was framed against a non-existent entity. The assessment order was quashed and set aside, with the assessee's appeal being allowed. The case establishes that valid legal entity existence is fundamental prerequisite for tax assessment proceedings. Case-Laws Income Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775234