Implenia Services and Solutions Pvt. Ltd. v. Dy. CIT (Bom.)(HC) (UR)

S. 148 : Reassessment-Notice-Notice issued to non-existing entity-Notice invalid-Notice could not be corrected u/s. 292B of the Act. [S. 147, 292B, Art. 226]

The notice u/s 148 was issued to non-existing entity. The assessee challenged the said notice by filing writ petition. Allowing the petition the Court held that notice issued to non-existing entity is bad in law which could not be corrected u/s. 292B of the Act.  The notice issued was quashed.  Order in Sky Light Hospitality LLP v ACIT (2005) 405 ITR 296 (Delhi)(HC),  Sky Light Hospitality LLP v ACIT(2018) 92 taxmann.com 93 (SC)  distinguished, followed PCIT v. Maruti Suzuki India Ltd (2019) 416 ITR 613 (SC).    (WP (L)  No. 14088/2021 dt  25-10-2021)

Implenia Services and Solutions Pvt. Ltd. v. Dy. CIT (Bom.)(HC) (UR)