Assessee sought deactivation of old PAN, and the department’s grievance portal recorded that, as per ITBA, old PAN stood merged with assessee’s PAN.  Assessee filed its return and assessment was completed under section 143(3). Subsequently, a notice under section 148A(b) was issued in the name of the predecessor with the old PAN on the ground that no return was filed under that PAN. The assessee replied that the predecessor had merged, all transactions were recorded in the assessee’s books/PAN, and returns had been filed and assessed. Thereafter, another notice under section 148A(b) was issued asking the assessee to explain whether transactions shown under the old PAN had been offered to tax. On writ, the Court held that the assessee furnished all details and asserted that all such transactions were duly accounted for in the assessee’s PAN. Ignoring the reply, the authority passed an order under section 148A(d) recording prima facie satisfaction to reopen assessment and issued a notice under section 148  Court held that  in spite of filing reply by assessee intimating that such PAN number was deactivated in the year 2009, the Assessing Officer did not pay any heed to such reply and solely relied upon information available on system. High Court held that there was total non-application of mind on behalf of the Assessing Officer, as well as negligence on his part for not verifying data provided by the assessee in replies time and again by disclosing that the old PAN was not active since 2009; therefore, the order passed under section 148A(d) and the notice issued under section 148 were quashed and set aside; the SLP of the revenue was dismissed. (AY. 2017-18)