notice u/s 148 of the Act
on the non-existent entity, has rendered the entire reassessment as
void ab-initio ... issue in
dispute and then held that assessment proceedings against
nonexistent entity can't be sustained. The relevant fining of Hon'ble
High
fact that the same being
passed in the name of 3 nonexistent entity, is illegal and void ab-
initio.
3. On the circumstances and facts
Limited and
assessee has argued that the assessment completed on a non-entity is void abinito.
We further note that ... jurisdiction to issue a notice in the name of
a nonexistent entity. It emerged at the outset during the course of hearing that there
arises
established that the
donor/lender is a bogus entity or a nonexistent entity, or that
their identity has not been proved.
11. The procedure
found that assessment is framed in the name of nonexisting entity, it does
not remain a procedural irregularity of ht nature which could be cured
facts in upholding the validity of the
assessment order on the nonexistent entity and not
following the decisions of the Hon'ble Jurisdictional
High
reason that
assessment had been made on a nonexistent entity. The appellant had
ceased to exist w.e.f 04.04.2004. In this regard, a supplementary ... ground that assessment had been made on a nonexistent entity,
the same fact of which prevails in the instant wealth tax case
amount by Assessing
Officer as taxable income in the hands of nonexistent entity and
consequential tax calculation and levy of interest. These being
assessment order being passed in the name of a nonexistent
entity. However, at the time of hearing, on instructions, Ld.
Counsel did not press
transactions with these entities by the appellant were not denied
under which the shares allotted in IPO by these fictitious entities
were transferred to them ... documents, PAN, etc. In fact however the
address of all these nonexistent entities is same.
9. While the appellant relied on the ratio of DharamDeo
