Clean-slate corporate sales prevent reassessment for extinguished liabilities, while section 148A orders cannot add unnotified allegations.

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....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.....