Issues: (i) Whether delay in filing the appeals challenging taxation of compensation received under the BSNL Voluntary Retirement Scheme, 2019, should be condoned; (ii) Whether compensation received under the BSNL Voluntary Retirement Scheme, 2019, constitutes retrenchment compensation exempt under Section 10(10B) of the Income-tax Act, 1961.

Issue (i): Whether delay in filing the appeals challenging taxation of compensation received under the BSNL Voluntary Retirement Scheme, 2019, should be condoned.

Analysis: The assessees had filed their returns on the basis of professional advice and subsequently raised the exemption claim. The explanations for delay disclosed sufficient cause, and substantial justice was preferred over procedural delay. Differing treatment by first appellate authorities on identical facts also warranted a consistent approach.

Conclusion: The delay was liable to be condoned, in favour of the assessees.

Issue (ii): Whether compensation received under the BSNL Voluntary Retirement Scheme, 2019, constitutes retrenchment compensation exempt under Section 10(10B) of the Income-tax Act, 1961.

Analysis: The BSNL scheme formed part of a Government-approved revival plan aimed at workforce reduction. Applying the binding coordinate-bench view on identical facts, the compensation under the scheme was characterised as retrenchment compensation under Section 10(10B), rather than voluntary-retirement compensation governed by Section 10(10C). The absence of a contrary jurisdictional High Court decision supported following that consistent view.

Conclusion: The compensation is a capital receipt exempt from tax under Section 10(10B) of the Income-tax Act, 1961, in favour of the assessees.

Final Conclusion: The impugned first appellate findings were set aside, and the assessees may furnish revised computations to the jurisdictional Assessing Officers for verification and consequential tax refund, where due.

Ratio Decidendi: Compensation paid under the BSNL Voluntary Retirement Scheme, 2019, as part of the Government-approved workforce-reduction revival plan, is retrenchment compensation qualifying for exemption under Section 10(10B) of the Income-tax Act, 1961.

Issues: Whether capital losses validly determined for an earlier assessment year can be denied carry forward and set-off merely because they were inadvertently omitted from the carried-forward-loss schedule in an intervening year's return.

Analysis: The return for A.Y. 2019-20 was filed within the prescribed time and the short-term and long-term capital losses declared therein were accepted and determined. The statutory entitlement to carry forward those losses consequently crystallised under the provisions governing carry forward and set-off. An inadvertent non-reporting of the carried-forward short-term loss in Schedule CFL of the A.Y. 2020-21 return was a technical procedural lapse; it neither affected the genuineness or determination of the losses nor extinguished the substantive entitlement arising from the timely return for the year in which the losses were incurred.

Conclusion: The assessee is entitled to carry forward the losses of A.Y. 2019-20 and set them off against eligible capital gains of the relevant year, in favour of the assessee.

Issues: Whether the writ jurisdiction should be invoked to challenge suspension and cancellation of GST registration when an appellate remedy is available.

Analysis: The cancellation followed a show-cause notice to which the registered person had replied. Although revocation of cancellation under Section 30 contemplates an opportunity of hearing before rejection of a revocation application, Section 107 permits an aggrieved person to appeal against any decision or order under the Central Goods and Services Tax Act, 2017. The unconsidered representation did not bar recourse to that appellate remedy. In these circumstances, the extraordinary jurisdiction under Article 226 was not warranted.

Conclusion: The challenge must be pursued through the statutory appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017.

Issues: Whether deduction for capital gains reinvestment is available where the new residential property is acquired jointly with the assessee's spouse and a part of the sale proceeds is transferred to the spouse for that acquisition.

Analysis: Section 54 requires investment of the capital gains in purchase of a new residential property and does not require the property to be acquired exclusively in the assessee's name. The assessee retained joint title, control and domain over the new property; the spouse was not a third party or stranger. The entire investment originated from the sale proceeds of the original property, including the amount transferred to the spouse. The deeming ownership and clubbing provisions applicable to transfers of house property and income to a spouse support treating the arrangement as not disentitling the assessee from the benefit. The precedent concerning acquisition exclusively in an adopted son's name was distinguishable because the assessee there had relinquished his rights in favour of a third person.

Conclusion: Deduction under Section 54 cannot be denied merely because the new residential property was purchased jointly with the assessee's wife; the assessee is entitled to the claimed deduction.

Issues: Whether the imported liquid crystal display touch-panel modules were classifiable under Customs Tariff Heading 90138010 rather than Customs Tariff Heading 8537 10.

Analysis: Liquid crystal displays are specifically covered by Heading 9013 unless they constitute articles more specifically provided under another heading. A chapter note that draws goods into another classification despite an exclusion must be construed narrowly. The use of LCDs as components in an automobile audio system does not itself displace their specific classification under Heading 9013. The material explaining classification under Heading 90138010 required consideration in accordance with the governing Chapter 90 framework.

Conclusion: The classification issue must be redetermined under Chapter 90, with the petitioner's claim for classification under Customs Tariff Heading 90138010 reconsidered afresh.

Outcome: The writ petition was disposed of by granting liberty to the petitioner to file an appeal against the impugned order-in-original within two weeks with statutory pre-deposit and a delay condonation application, and the appellate authority was directed to consider delay and decide the appeal in accordance with law.

Outcome: The writ petition was disposed of by relegating the petitioner to the statutory appellate remedy, with liberty to file an appeal with a delay condonation application and pre-deposit, and interim protection against coercive recovery for the stipulated period.

Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 for Assessment Year 2015-16 was barred by limitation and liable to be set aside.

Analysis: The assessment year in question was 2015-16. The Supreme Court had clarified that, where the proceedings pertain to Assessment Year 2015-16, reassessment notices issued or proposed to be issued would stand barred by time in light of the concession recorded in Rajeev Bansal. Since the impugned notice was issued on or after 1 April 2021 and related to Assessment Year 2015-16, it fell within the category of time-barred notices referred to by the Supreme Court.

Conclusion: The notice under Section 148 was held to be time-barred and was set aside, and all consequential action taken pursuant to it was quashed.

Issues: (i) Whether the revision under section 263 of the Income-tax Act, 1961 could be sustained on the ground that depreciation on goodwill arising from a slump sale/business transfer was wrongly allowed. (ii) Whether the revision under section 263 of the Income-tax Act, 1961 could be sustained on the ground that professional, valuation, legal, structuring and consultancy fees were capital in nature and were allowed without proper verification.

Issue (i): Whether the revision under section 263 of the Income-tax Act, 1961 could be sustained on the ground that depreciation on goodwill arising from a slump sale/business transfer was wrongly allowed.

Analysis: The business was acquired under a business transfer agreement on slump sale terms, not by amalgamation. The revisionary order proceeded on the mistaken premise that amalgamation provisions governed the transaction. The assessment records also showed that the Assessing Officer had examined the valuation material and the depreciation claim. Where the Assessing Officer adopts one of two possible views on allowance of depreciation on goodwill in such a transaction, the order cannot be treated as erroneous merely because the revisional authority prefers a different view.

Conclusion: The revision on this issue was not sustainable and was liable to be set aside in favour of the assessee.

Issue (ii): Whether the revision under section 263 of the Income-tax Act, 1961 could be sustained on the ground that professional, valuation, legal, structuring and consultancy fees were capital in nature and were allowed without proper verification.

Analysis: The expenditure was incurred in connection with acquisition and reorganisation of business and was supported by the business purpose of facilitating the assessee's operations. The material on record showed that the Assessing Officer had considered the claim, and the revisional order recorded only a brief objection without demonstrating how the allowance was unsustainable. On the facts, the expenditure was treated as revenue in nature and the view taken by the Assessing Officer could not be branded as a lack of enquiry warranting revision.

Conclusion: The revision on this issue was also not sustainable and was liable to be set aside in favour of the assessee.

Final Conclusion: The revisional order was quashed and the assessee's appeal succeeded.

Ratio Decidendi: Section 263 cannot be invoked where the Assessing Officer has taken a plausible view after examination of the material, and a revisionary authority cannot sustain interference by proceeding on an incorrect assumption about the applicable transaction regime.

Issues: Whether the addition made on protective basis in the hands of the assessee in respect of the World Cup receipts and surplus was justified, and whether PILCOM could be treated as an independent assessable entity or association of persons for taxing the disputed income.

Analysis: The assessment records and the financial arrangements between the cricket boards showed that the receipts and expenses were allocated according to the venues and agreed sharing mechanism, with the assessee accounting for the receipts and surplus relatable to matches played in India. The appellate authority found that PILCOM was only a coordinating and managing committee without independent existence for earning income, and that the income attributed by the Assessing Officer to PILCOM had already been dealt with in the relevant hands or was not received or receivable by the assessee, particularly in respect of matches played outside India. The Tribunal agreed that the Assessing Officer was not justified in making a protective assessment on the footing that PILCOM was an independent taxable entity or in taxing the balance foreign-match receipts and related items in the assessee's hands.

Conclusion: The protective additions were correctly deleted and the assessee's returned treatment was upheld; the Revenue's appeal fails.

Issues: (i) Whether an assessment order issued in FORM GST DRC-07 without the assessing officer's signature is valid and can be sustained. (ii) Whether service of the order by uploading it on the GST portal is sufficient, and whether the writ petition could be entertained despite delay, subject to a deposit condition.

Issue (i): Whether an assessment order issued in FORM GST DRC-07 without the assessing officer's signature is valid and can be sustained.

Analysis: The absence of signature on the assessment order was treated as a patent defect. The decision followed earlier Division Bench rulings holding that a signature on the assessment order is not dispensable and that the curative provisions regarding mistakes or service cannot validate such a defect.

Conclusion: The assessment order was held invalid and liable to be set aside.

Issue (ii): Whether service of the order by uploading it on the GST portal is sufficient, and whether the writ petition could be entertained despite delay, subject to a deposit condition.

Analysis: Portal upload was considered in the context of service under the GST regime, but the Court balanced the practical difficulties faced by registered persons with the need to preserve revenue administration. The Court also took note of the hardship caused by online administration and the need to permit delayed writ petitions in appropriate cases, on a conditional basis.

Conclusion: The writ petition was entertained, the delay was effectively not treated as fatal, and the challenge was allowed subject to deposit of 20% of the disputed tax, with remand to the Assessing Officer for fresh adjudication after hearing the petitioner.

Final Conclusion: The impugned assessment was set aside for want of signature and the matter was remanded for fresh decision after hearing, with the petitioner required to make the stipulated tax deposit and with limitation excluded for the intervening period.

Ratio Decidendi: An assessment order under the GST regime that suffers from the foundational defect of absence of the assessing officer's signature is invalid, and such a defect is not cured by the statutory provisions governing mistake or modes of service.

Issues: Whether the reassessment notice and the order disposing objections for Assessment Year 2016-17 were sustainable when they were founded on audit objections and on matters already examined in the original scrutiny assessment.

Analysis: The reopening was issued within four years, so the first proviso to Section 147 of the Income-tax Act, 1961 was not attracted. However, the record showed that the very issues on which reopening was sought, including deduction under Section 80G, additional depreciation, deduction under Section 32AC, depreciation on computer software, depreciation on goodwill, deduction under Section 35(2AB), legal and professional expenses, non-target based gifts and club membership expenses, had already been specifically queried during the original proceedings under Section 142(1) and were replied to by the assessee. The original assessment under Section 143(3) was thus formed after consideration of those matters. The only basis for reopening was the audit party's objections, which did not constitute fresh tangible material. Reopening on such material would amount to a mere change of opinion. The Court also held that the assessee's claims regarding additional depreciation on computers, carry forward of balance depreciation, and goodwill could not justify reopening in the facts of the case.

Conclusion: The reassessment notice under Section 148 and the order rejecting objections were unsustainable and were quashed and set aside.

Issues: Whether the appeal against the order directing reconsideration of the resolution plan and deferring consideration of the appellant's interlocutory application was maintainable at this stage, or was premature.

Analysis: The impugned order did not finally decide the appellant's request for intervention or other substantive reliefs in the interlocutory application; those matters were kept open to be considered when the revised resolution plan was placed before the adjudicating authority after reconsideration by the committee of creditors. Since the appellant did not challenge the part of the order remitting the plan back to the committee of creditors, and the claimed grievance was contingent upon future reconsideration and resubmission of the plan, no immediate prejudice or crystallized cause of action was shown.

Conclusion: The appeal was premature and not maintainable at this stage.

Issues: (i) Whether notifications issued by the Central Government under Sections 9 and 11 of the Central Goods and Services Tax Act, 2017 could travel beyond the recommendations of the GST Council; (ii) Whether the GST Council had the power to ratify the notifications issued by the Central Government under Sections 9 and 11 of the Central Goods and Services Tax Act, 2017.

Issue (i): Whether notifications issued by the Central Government under Sections 9 and 11 of the Central Goods and Services Tax Act, 2017 could travel beyond the recommendations of the GST Council.

Analysis: The GST Council's recommendations are binding on the Government when it exercises subordinate law-making power under the GST regime. Notifications issued under Sections 9 and 11 must therefore be made "on the recommendations" of the Council. The impugned notifications, while tracing their source to the Council's recommendation, added the expression "enforceable right in a court of law" and the related affidavit mechanism, which were not part of the recommendation. This amounted to an expansion beyond the Council's approved text. The addition could not be sustained as being supported by the recommendation itself.

Conclusion: The notifications were ultra vires to the extent they introduced the expression "enforceable right in a court of law"; in all other respects, they remained valid.

Issue (ii): Whether the GST Council had the power to ratify the notifications issued by the Central Government under Sections 9 and 11 of the Central Goods and Services Tax Act, 2017.

Analysis: The Constitution confers on the GST Council the power to make recommendations, not to ratify prior unauthorised notifications. Ratification is not an inherent power of a constitutional or statutory body and must be expressly conferred or necessarily implied. Since neither Article 279A nor any statute granted such power to the GST Council, its subsequent approval could not validate the notifications already issued beyond recommendation.

Conclusion: The GST Council had no jurisdiction to ratify the impugned notifications, and the purported ratification was ineffective.

Final Conclusion: The challenge succeeded in part: the impugned notifications were struck down only to the extent of the unauthorized enlargement, the consequential show cause notices were set aside, and the writ petitions were allowed.

Ratio Decidendi: When the GST Council's recommendation is the statutory foundation for notification-making under the GST enactment, the Government cannot enlarge the content of the notification beyond that recommendation, and the Council cannot retrospectively validate such excess by ratification absent an express constitutional or statutory power.

Issues: Whether reassessment proceedings initiated on the basis of search material were governed by the earlier reassessment regime under Section 152(3) of the Income-tax Act, 1961, and whether the notice issued under Section 148 for Assessment Year 2021-22 was barred by limitation under Section 149.

Analysis: The search was conducted on 18.11.2023, i.e. within the period covered by Section 152(3), so the reassessment provisions as they stood before the Finance (No. 2) Act, 2024 applied. The reopening was founded on material allegedly found during search and the assessee's statement, but the relevant assessment year ended on 31.03.2022. Since the notice under Section 148 was issued on 23.05.2025 and the alleged escaped income was below the threshold for the extended period, the notice fell beyond the three-year limit under Section 149(1)(a).

Conclusion: The notice under Section 148 was time-barred and the reassessment could not be sustained.

Final Conclusion: The reopening was quashed because the reassessment was governed by the earlier regime, yet the notice was issued beyond the permissible limitation period.

Ratio Decidendi: Where reassessment is initiated on the basis of a search falling within the period covered by Section 152(3), the earlier reassessment regime applies, but the notice must still satisfy the limitation prescribed under Section 149; a notice issued beyond that period is invalid.

Issues: Whether the notice issued under Section 148 for Assessment Year 2015-16 was barred by limitation and liable to be quashed.

Analysis: The matter was revived in view of the Supreme Court's remand in connected litigation and the admitted position that the impugned notice had been issued on or after 1 April 2021 for Assessment Year 2015-16. In such cases, the governing concession recorded before the Supreme Court in Rajeev Bansal applied, and no further adjudication was required once the assessment year was found to be 2015-16. The challenge to the notice therefore succeeded on the ground of limitation.

Conclusion: The notice under Section 148 was held to be time-barred and was set aside, and all consequential action taken pursuant to it was quashed.

Issues: (i) Whether non-issuance of a fresh notice under section 143(2) after filing of the revised return vitiated the assessment. (ii) Whether the addition of unexplained cash deposits under section 69A could be sustained in full, and whether the enhanced rate under section 115BBE applied to the assessment year in question.

Issue (i): Whether non-issuance of a fresh notice under section 143(2) after filing of the revised return vitiated the assessment.

Analysis: The revised return did not disclose any fresh source of income, additional claim affecting returned income, or variation in the computation of total income. The only change was a claim for TDS credit, while the returned income remained unchanged. In such circumstances, the original scrutiny notice continued to be valid and no prejudice from the absence of a second notice was shown.

Conclusion: The challenge to the assessment on the ground of non-issuance of a fresh notice under section 143(2) failed and was rejected.

Issue (ii): Whether the addition of unexplained cash deposits under section 69A could be sustained in full, and whether the enhanced rate under section 115BBE applied to the assessment year in question.

Analysis: A sum of cash already assessed to tax in an earlier year could not again be brought to tax as unexplained income in the year under consideration. Further relief was warranted on the facts, including the assessee's status as a senior citizen and the surrounding circumstances of the cash deposits. The enhanced rate under section 115BBE introduced by the later amendment was held inapplicable to the assessment year involved.

Conclusion: The addition was sustained only to the extent of Rs. 2,00,000, the balance was deleted, and the higher amended rate under section 115BBE was held inapplicable.

Final Conclusion: The assessment survived only in part, with substantial relief granted on the merits and the tax computation directed to be revised accordingly.

Ratio Decidendi: Where a revised return does not alter the returned income or introduce any fresh material requiring scrutiny, a fresh notice under section 143(2) is not mandatory; and an amount already taxed in an earlier year cannot again be assessed as unexplained income in a later year, while a later enhanced tax rate cannot be applied retrospectively absent legislative mandate.

Issues: (i) deduction under section 36(1)(viia) and Rule 6ABA on rural branch advances and branch profits; (ii) taxability of unrealized gains on revaluation of foreign exchange forward contracts; (iii) allowability of corporate social responsibility expenditure and trust-related expenses under section 37(1); (iv) depreciation on ATMs, note-counting machines and electronic weighing machines; (v) disallowance under section 14A read with Rule 8D; (vi) depreciation on HTM, HFT and AFS securities; (vii) deduction under section 36(1)(viii) in respect of special reserve; (viii) taxability of interest on securities only when due; and (ix) applicability of section 115JB to banking companies.

Issue (i): Whether deduction under section 36(1)(viia) and Rule 6ABA was correctly allowed on the assessee bank's claim computed on the basis of aggregate average advances and eligible branch profits.

Analysis: The claim had already been accepted in the assessee's own case for earlier assessment years on identical facts. The computation dispute raised by the Revenue on the treatment of rural branch advances and overseas branch profits stood covered by prior co-ordinate bench decisions, and no contrary material or distinguishing fact was shown.

Conclusion: The deduction was rightly allowed and the Revenue's objection failed.

Issue (ii): Whether unrealized gains on revaluation of foreign exchange forward contracts were taxable in the year under consideration.

Analysis: The same issue had been decided in the assessee's favour by the jurisdictional Tribunal and affirmed by the jurisdictional High Court in the assessee's own case. In the absence of any change in facts or any contrary authority, the addition on account of notional revaluation gain could not survive.

Conclusion: The deletion of the addition was upheld in favour of the assessee.

Issue (iii): Whether CSR expenditure and trust-related expenditure were allowable under section 37(1).

Analysis: The disallowance had been made by invoking section 135 of the Companies Act, 2013 and Explanation 2 to section 37(1). The appellate authority followed the earlier decision in the assessee's own case, and the Revenue did not show any material change in facts or law.

Conclusion: The expenditure was held allowable and the disallowance was not sustained.

Issue (iv): Whether depreciation on ATMs was allowable at 60% and whether the same rate applied to note-counting machines and electronic weighing machines.

Analysis: Binding jurisdictional precedent treated ATMs as computers eligible for depreciation at 60%. The same functional equivalence was not extended to note-counting machines and electronic weighing machines, which remained in the plant and machinery category.

Conclusion: Depreciation at 60% on ATMs was correctly allowed, and the Revenue's challenge failed.

Issue (v): Whether disallowance under section 14A read with Rule 8D was warranted on the assessee's exempt income and investments.

Analysis: The appellate authority applied settled principles that interest disallowance is not justified where own funds exceed investments, and directed verification on that aspect. It also relied on the banking-specific position regarding investments and the requirement to examine the character of SLR and non-SLR holdings for administrative disallowance.

Conclusion: No infirmity was found in the appellate order and the section 14A disallowance did not survive as made by the Revenue.

Issue (vi): Whether depreciation on HTM, HFT and AFS securities was allowable as business expenditure.

Analysis: The issue had already been decided in the assessee's favour by co-ordinate benches and by the jurisdictional High Court in the assessee's own case. The Revenue did not bring any distinguishing precedent or factual change.

Conclusion: The deletion of the disallowance was upheld.

Issue (vii): Whether deduction under section 36(1)(viii) was available in respect of special reserve and the method of recomputation adopted by the appellate authority was erroneous.

Analysis: The appellate authority followed the earlier tribunal view on the method of computation and also held that a reserve created in a later year could not substitute the statutory requirement that the reserve be created out of relevant year profits. The Revenue failed to show any error in that approach.

Conclusion: The relief granted by the appellate authority was sustained.

Issue (viii): Whether interest on securities was taxable only on the specified dates when it became due.

Analysis: The question stood covered by the jurisdictional High Court in the assessee's own case, and the principle had been affirmed by the Supreme Court in the context of broken-period interest. Interest not yet due could not be brought to tax merely on accrual notions contrary to that binding position.

Conclusion: The assessee's treatment was upheld and the Revenue's ground failed.

Issue (ix): Whether section 115JB applied to banking companies.

Analysis: The issue was already decided against the Revenue in the assessee's own case by co-ordinate bench decisions. No contrary authority or legislative change was shown to dislodge that view.

Conclusion: Section 115JB was held inapplicable to the assessee bank.

Final Conclusion: All disputed additions and disallowances were rejected, the appellate relief granted to the assessee was sustained, and the Revenue's appeal did not succeed.

Ratio Decidendi: Where an identical issue in the assessee's own case has been conclusively decided by binding jurisdictional precedent and no distinguishing fact or contrary authority is shown, the same view must be followed; in banking matters, CSR disallowance, depreciation claims, section 14A computation, securities valuation, special reserve deduction, interest-tax timing, and MAT applicability all turn on the settled precedent applicable to the assessee's business model and statutory framework.

Issues: Whether the assessing authority could issue a second show cause notice and pass a fresh adjudication order after the matter had already been remanded with a direction to adjudicate the first notice after granting personal hearing and considering the reply.

Analysis: The directions in the earlier round required the assessing authority to proceed on the basis of the first show cause notice, afford personal hearing, and consider the reply before passing a fresh order. Instead of complying with that course, the authority issued a second show cause notice and proceeded to adjudication. Such a course was held impermissible because it departed from the binding directions issued in the earlier writ proceedings and amounted to overreaching the Court's order. The Court therefore interfered with the impugned adjudication on that legal ground alone, without entering into the merits of the tax demand.

Conclusion: The impugned adjudication order was set aside and the matter was remanded to the assessing authority to pass an order on the first show cause notice after granting personal hearing and considering the reply in accordance with law.

Issues: (i) Whether a reassessment notice and consequential assessment order issued in the name of a company that had already been struck off and ceased to exist were valid. (ii) Whether Section 250 of the Companies Act, 2013 could save the liability of the dissolved company for purposes of reopening.

Issue (i): Whether a reassessment notice and consequential assessment order issued in the name of a company that had already been struck off and ceased to exist were valid.

Analysis: The company had been dissolved before the reopening notice was issued. The notice under Section 148 of the Income-tax Act, 1961 was therefore issued to a non-existent entity. The established rule applied was that proceedings initiated against an entity which has ceased to exist are legally untenable, and participation in such proceedings does not cure the defect. Since the reassessment notice itself was invalid, the assessment order founded upon it could not survive.

Conclusion: The notice under Section 148 and the consequential assessment order were quashed as invalid for having been issued against a non-existent entity.

Issue (ii): Whether Section 250 of the Companies Act, 2013 could save the liability of the dissolved company for purposes of reopening.

Analysis: The contention based on Section 250 of the Companies Act, 2013 was rejected because, on the date of the reopening notice, the company had already been struck off and there was no subsisting company liability or obligation to be enforced through that provision. The argument that restoration steps could be taken was left open, but it did not validate the impugned proceedings.

Conclusion: Section 250 of the Companies Act, 2013 did not validate the reopening notice or the assessment order.

Final Conclusion: The writ petition succeeded, and the impugned reassessment proceedings were set aside on the ground that they were initiated against a dissolved company.

Ratio Decidendi: Tax proceedings initiated in the name of an entity that has ceased to exist are void, and the defect is not cured by later participation or by a consequential assessment founded on such invalid initiation.