Clean-slate sale of a corporate debtor as a going concern...

Clean-slate sale of a corporate debtor as a going concern extinguishes pre-existing liabilities and investigations, preventing reassessment from being based on an alleged earlier interest liability. Reopening cannot rest on conjecture that unpaid interest was deducted or that a liability ceased where available accounts could verify the claim and the section 148A order itself records no cessation. An order under section 148A must remain within the show-cause notice; adding an unrelated bogus-purchase allegation without notice or hearing breaches natural justice and indicates non-application of mind. On these grounds, the reassessment notice and section 148A order were quashed.