Tax Reassessment Notices Invalid for Non-Existent Entities Post-Amalgamation, Despite Active PAN from Prior Years.

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....Reassessment notices issued to a non-existing entity - Amalgamation - The fact that PAN was not deactivated would not help the Revenue because there could be cases relating to various years when the company was in existence and it is possible those PAN numbers are picked up for scrutiny or for issuance of refund. That in our view, will not be a sanction for Department to issue notices to a non-existing entity, particularly, when they were aware that the entity was not in existence. - HC....