https://www.taxtmi.com/caselaws?id=781849 HC held that its earlier order merely clarified that revenue could, in law, initiate fresh proceedings against the transferee company and did not contain any "finding" or "direction" under s.153(6). Applying the principle that no assessment can be framed on a non-existent entity, the HC found that consideration of assessment in the hands of the transferee was unnecessary to decide the earlier appeal. Consequently, s.153(6) was inapplicable and the assessment against the transferee for AY 2007-08 was barred by limitation under s.153(1). Reliance on earlier HC and SC decisions did not assist the Revenue. en-us Mon, 17 Nov 2025 00:00:00 +0530 Fri, 21 Nov 2025 08:42:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781849 HC held that its earlier order merely clarified that revenue could, in law, initiate fresh proceedings against the transferee company and did not contain any "finding" or "direction" under s.153(6). Applying the principle that no assessment can be framed on a non-existent entity, the HC found that consideration of assessment in the hands of the transferee was unnecessary to decide the earlier appeal. Consequently, s.153(6) was inapplicable and the assessment against the transferee for AY 2007-08 was barred by limitation under s.153(1). Reliance on earlier HC and SC decisions did not assist the Revenue. Case-Laws Income Tax Mon, 17 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781849