2026 (1) TMI 828

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....red to as 'AO') issued under Section 148A(1) so also the order issued under Section 148A(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act of 1961') dated 27.06.2025, inter alia, on the ground that the notice and the consequential order is bad in the eyes of law having been issued to a dissolved company. 2. Apprising the Court about the facts of the case, learned counsel for the petitioner submitted that 'Grimme India Private Limited' (hereinafter referred to as the 'erstwhile company') was a company registered in India, in which the petitioner, a company registered in Germany was a shareholder having a 99.99% shareholding; said company went into the process of liquidation and during such process, a certificate dated 16....

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....by the liquidator was payment made to a supplier and the residual amount lying in the bank account. 6. Learned Senior Standing Counsel for the respondents per contra submitted that the present petitioner might have filed reply to the notice dated 31.03.2025, but since the petitioner was not the assessee, no cognizance could be taken of such reply on the centralized Income Tax Business Application (hereinafter referred to as 'ITBA') portal. He argued that it was in such situation, the order dated 27.06.2025 was passed, observing that no reply has been filed by the noticee. 7. So far as the issuing of certificate under Section 178 of the Act of 1961 so also the fact that the said company stood dissolved on 31.10.2023, are concerned, no ....