Amalgamation Does Not Exempt Pre-Approval Tax Liabilities; Assessed Liabilities Remain Final Per Finance Act, 1994.

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....Refund claim - amalgamation of two entities - any transaction that creates liability or generates an asset in the books of the transferor is afforded the privilege of artificial life - tax liability discharged before the actual date of approval of amalgamation under Finance Act, 1994 pertains to existence as separate persons and, therefore, not immunized therefrom. - The assessed liability under Finance Act, 1994, duly discharged and being neither provisional nor tentative, is beyond the scope of re-determination of levy merely because of a scheme of amalgamation. - AT....