Amalgamation assessment: Predecessor's pre-merger income cannot be clubbed with successor's assessment in a single order; reassessment invalidated.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Amalgamation assessment: the commentary concludes that income and disallowances of a predecessor for a period prior to amalgamation cannot be merged into a single reassessment order framed against the successor; such pre-amalgamation amounts must be assessed separately and, if at all, only under representative assessment provisions, and reliance on decisions about notices in the name of non-existent entities does not justify clubbing the predecessors income with the successors in one composite assessment. The revenues reassessment attempts to add predecessor period income in a single order are therefore unsustainable.....