Reassessment against a struck-off company is invalid when the notice is issued after the entity ceases to exist.

Reassessment proceedings cannot be sustained where the assessee company had already been struck off and had ceased to exist before issuance of the section 148 notice. The assessment machinery could not validly continue against a non-existent entity, and the consequential reassessment order also lacked legal force. The notice and assessment order were therefore quashed as unsustainable.

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Issues: Whether the reassessment notice and the consequential assessment order could be sustained against a company that had already been struck off before issuance of notice under section 148.

Analysis: The company had ceased to exist long before the notice under section 148 was issued. The respondent also ed on oath that the company had already been struck off prior to issuance of the notice and that the petition was in order on that basis. In these circumstances, the reassessment and the consequential assessment could not survive against a non-existent entity.

Conclusion: The reassessment notice and the assessment order were unsustainable and were quashed, in favour of the assessee.

Ratio Decidendi: Proceedings under the reassessment provisions cannot be continued against an entity that had ceased to exist before issuance of the statutory notice.

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