The resolution plan of the corporate debtor provided that all assessed and unassessed tax liabilities under the Income-tax Act would stand waived and extinguished upon approval of the resolution plan. The High Court held that, once the resolution plan was approved and all tax liabilities stood extinguished, there was no occasion for the Revenue to issue a notice under section 148 in respect of such liabilities. Accordingly, the reassessment notice was not sustainable. (AY. 2021-22)