Assessment against a non-existent company is void; reassessment after liquidation cannot be sustained in law.

An assessment initiated in the name of a company that had already been liquidated and ceased to exist in law is void and unsustainable. Proceedings against a non-existent entity are a nullity, and the defect is not cured by the fact that the notice or reassessment was issued after liquidation. The assessment was therefore quashed as invalid, and the Revenue's challenge failed because the foundational proceedings themselves were annulled for being framed against an entity no longer in existence.

---

---

Issues: Whether the assessment framed in the name of a company that had already been liquidated and ceased to exist in law was valid.

Analysis: The notice initiating reassessment was issued after the company had liquidated. An assessment made in the name of a non-existent entity cannot be sustained in law. The conclusion was supported by judicial precedents holding that proceedings against an entity which no longer exists are a nullity.

Conclusion: The assessment was quashed as invalid and void.

Final Conclusion: The assessee's appeal was withdrawn, and the Revenue's appeal failed because the assessment itself was annulled for having been made against a non-existent company.

Ratio Decidendi: An assessment made in the name of a company that had ceased to exist before initiation of proceedings is void and cannot be sustained.

---