The assessee (transferee) company and transferor company proposed a scheme for amalgamation with appointed dated 1-4-2018. Amalgamation process was approved by NCLT.The proposed scheme of amalgamation was also informed to the revenue. The Revenue issued notice under section 148A against the transferor company specifying therein that the PAN of the transferor company was active. Assessee submitted that all the transactions entered and appeared on the PAN of transferor company had been duly accounted by the assessee-company in accordance with the generally accepted accounting policy and other applicable laws. The Assessing Officer passed order u/s 148A(d) of the Act. On writ the Court held that the  notice was given to the Transferor company, which is a non-existent entity, after the appointed date, i.e. 1-4-2018. The order under section 148A(d) has been passed by the revenue against a non-existent entity. Order is held to be bad in law.  (AY. 2019-20)