Court Upholds Assessment Notice Validity u/s 147 Despite Amalgamation; Original Company Considered Operational Post-Merger.

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....Validity of reopening of assessment u/s 147 - notice issued to a company which is non-existent on the date as it stood amalgamated with the appellant/petitioner - ts conduct of filing return of income in the name of OAS after the amalgamation and obtained refunds issued in the name of OAS, which will all go to show that M/s.OAS continued to exist even after amalgamation. - Therefore, appellant cannot canvass the point that OAS was nonexistent and the proceedings initiated in its name would be bad in law. - HC....