The petitioner has challenged the notice dated 28-3-2018 issued under section 148 of the Act  for the  assessment year 2011-12 and the order of overruling the objections dated 29-11-2018 as well as the notice dated 11-12-2018 issued under section 142(1) of the Act on the ground that  notice issued under Section 148 of the Act impugned herein, is without jurisdiction as issued on the non-existing company and the same is nothing but change of opinion without any tangible material moreover, beyond the period of limitation prescribed under the first proviso to Section 147 of the Act.  Allowing the petition  the court held that, assessee company was amalgamated with another company and thereby lost its existence, jurisdiction assumed by Assessing Officer to issue notice under section 148 to non-existing company was substantive illegality and not procedural violation of nature adverted to in section 292B and hence not curable. Therefore, notice issued under section 148 to non-existing company was to be quashed and set aside.  (AY. 2011-12)