Revisionary proceedings initiated in the name of non-existent entity is invalid

ITAT Kolkata held that revisionary proceedings u/s. 263 initiated in the name of non-existent entity, despite the fact that private limited company was converted into LLP and the conversion was brought to the knowledge of AO, is void ab initio and invalid.

Facts- Assessee filed its return declaring a total loss of Rs.6,04,635/-. The return was originally processed u/s. 143(1) of the Act. Thereafter, the case of the assessee was reopened u/s. 147 of the Act on the basis of information received from Investigation Wing that the assessee is beneficiary of Rs.4,95,00,000/- received from four entities and accordingly, the income has escaped assessment.

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