On writ the Court held that based on the  averments and the arguments, the fundamental error in issuing the impugned notices against a non-existing company despite full knowledge of the merger cannot be condone. The impugned notices, which are non-est cannot be treated as “good” as urged on behalf of the Respondents. In PCIT v. Maruti Suzuki Ltd (2019) 265 Taxman 515/ 416 ITR 613 (SC)

, the Hon’ble Supreme Court has held that issuing notice in the name of a non-existing company is a substantive illegality and not a mere procedural violation of the nature adverted to in Section 292B of the Act.  Notice and order is quashed and set aside. (AY. 2013-14 to 2019-20)