Invalid Tax Assessment Due to Dissolution: Missteps in Jurisdiction and Breach of Natural Justice for 2018-19 Year.

This case deals with the validity of assessment proceedings initiated against an amalgamated company for the assessment year 2018-19. The key points are: The Assessing Officer (AO) erroneously assumed jurisdiction u/ss 147/148/148A, alleging income had escaped assessment because the amalgamating company failed to file a return for AY 2018-19. However, the amalgamating company stood dissolved on March 30, 2018, and could not file a return. Only the amalgamated company was required to file, which it duly did. The consolidated accounts were assessed u/s 143(3). The AO failed to establish that items mentioned in the Section 148A(b) notice were not incorporated in the amalgamated company's accounts/return, resulting in escaped income. This vitia..... .....

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