Allowing the petition the Court held that the notice under section 148 of the Income-tax Act, 1961 which formed the basis for reassessment proceedings under section 147 was issued in the name of the assessee which was a non-existent entity due to amalgamation under the order of the court and despite the fact that the Department having been informed. The fact that the permanent account number in the name of the non-existent entity remained active did not create an exception to the principles enunciated in PCIT  v. Maruti Suzuki India Ltd (2019) 416 ITR 613 (SC).  The notice of reassessment and consequential demand notice and penalty notice for the assessment were set aside. (AY.2017-18)