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Issues: Whether notices issued under section 148A(b) for the relevant assessment year, addressed to a company that had ceased to exist on amalgamation, were valid in law.
Analysis: The petitioner had undergone amalgamation and the transferor entity had ceased to exist. The revenue was informed of the amalgamation before issuance of the notices. The notices, however, were issued in the name of the non-existing company and to its erstwhile PAN. A notice issued to an entity that is no longer in existence is a jurisdictional defect and amounts to a substantive illegality.
Conclusion: The notices were without jurisdiction and were set aside.
Ratio Decidendi: A reassessment notice issued in the name of a non-existent amalgamating company is void for want of jurisdiction and cannot be sustained.
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