Rectification of assessment orders cannot cure jurisdictional errors where orders name non-existent entities after mergers. An assessment order issued in the name of a non-existent entity after a disclosed corporate amalgamation was held to be a fundamental, jurisdictional ... Summary
Rectification of assessment orders cannot cure jurisdictional errors where orders name non-existent entities after mergers.
An assessment order issued in the name of a non-existent entity after a disclosed corporate amalgamation was held to be a fundamental, jurisdictional error not correctable under Section 154 or Section 292B; prior disclosure of the merger and absence of misleading conduct distinguished the case from precedents permitting clerical correction.
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