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    <title>No binding direction under s.153(6); reassessment of amalgamated company time-barred under s.153(1) for A.Y. 2007-08</title>
    <link>https://www.taxtmi.com/highlights?id=94373</link>
    <description>HC held that its earlier order setting aside assessments on the amalgamating, non-existent company did not contain any &quot;finding&quot; or &quot;direction&quot; within the meaning of s.153(6) of the Act. The prior order merely applied the ratio of Maruti Suzuki to quash assessments on a non-existent entity and clarified that fresh proceedings, if any, could be initiated against the amalgamated transferee in accordance with law, which did not amount to a binding direction. Consequently, the extended limitation under s.153(6) was inapplicable. The impugned assessment framed against the transferee company for A.Y. 2007-08 was therefore held to be time-barred under s.153(1), and stood quashed, with the Revenue&#039;s contentions rejected.</description>
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    <pubDate>Fri, 21 Nov 2025 08:42:31 +0530</pubDate>
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      <title>No binding direction under s.153(6); reassessment of amalgamated company time-barred under s.153(1) for A.Y. 2007-08</title>
      <link>https://www.taxtmi.com/highlights?id=94373</link>
      <description>HC held that its earlier order setting aside assessments on the amalgamating, non-existent company did not contain any &quot;finding&quot; or &quot;direction&quot; within the meaning of s.153(6) of the Act. The prior order merely applied the ratio of Maruti Suzuki to quash assessments on a non-existent entity and clarified that fresh proceedings, if any, could be initiated against the amalgamated transferee in accordance with law, which did not amount to a binding direction. Consequently, the extended limitation under s.153(6) was inapplicable. The impugned assessment framed against the transferee company for A.Y. 2007-08 was therefore held to be time-barred under s.153(1), and stood quashed, with the Revenue&#039;s contentions rejected.</description>
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      <pubDate>Fri, 21 Nov 2025 08:42:31 +0530</pubDate>
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