Reassessment against a non-existent company quashed where reopening notice was issued after striking off from the register.

Reassessment proceedings initiated under section 148 against a company already struck off from the register were invalid because the notice was issued to a non-existent entity, and the defect went to the root of jurisdiction. The reopening was quashed on that basis, and the remaining grounds were treated as academic.

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Issues: Whether reassessment proceedings initiated under section 148 against a company already struck off from the register could be sustained.

Analysis: The notice for reopening was issued after the company had been struck off under the Companies Act, 2013. Proceedings initiated against an entity that had ceased to exist were held to be invalid, and the defect went to the root of jurisdiction. The challenge to reopening was therefore accepted, while the remaining grounds were treated as academic.

Conclusion: The reassessment reopening was quashed as having been initiated against a non-existent entity, in favour of the assessee.

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