Assessment in Name of Amalgamating Bank Held Void – Order Passed on Non-Existent Entity Quashed Following Maruti Suzuki Principle

ACIT Vs Bank of Baroda (e- Vijaya Bank) (ITAT Mumbai) ITAT Mumbai quashed assessment order passed in the name of erstwhile Vijaya Bank (merged with Bank of Baroda w.e.f. 01.04.2019), holding that assessment framed on a non-existent entity is null & void in law. Tribunal observed that AO was fully aware of amalgamation during assessment proceedings, yet notices and final order were issued in the name of the amalgamating entity, rendering proceedings invalid. The Bench distinguished Skylight Hospitality LLP and relied on Maruti Suzuki India Ltd. and jurisdictional precedents to hold that def...