Held, allowing the petition, that the fact that the assessee was converted into a private limited company with the dissolution of the partnership firm on July 14, 2010. With such conversion the permanent account numbers were also altered. The documents that had been filed by the assessee in respect of which the proceedings were initiated pertained to exports made by the assessee with the same Importer-Exporter Code, and copies of the export shipping bills showed that the permanent account number of the company with the Importer-Exporter Code had been declared. Similarly, copies of the bills of entry also indicated that the bills of entry contained the permanent account number of the assessee-company with the same Importer-Exporter Code and not the permanent account number of the partnership firm which had expired with effect from July 14, 2010. The assessee had also filed copy of form 15CA acknowledgment with respect to remittance to non-resident or foreign company which also indicated the name of the assessee-company with the assessee’s permanent account number. On the other hand, the order itself had been passed in the name of the non-existing firm based on a notice that was issued in the name of non-existing firm. All along the assessee had replied to the Department. However, the Department had failed to take note of the same and had thus confirmed the demand. The Assistant Commissioner had also rightly dropped the proceedings by an order, under section 148A(d) for the subsequent assessment year 2016-2017. The notice issued under section 148 and the order passed under section 147 read with sections 144 and 144B were arbitrary and showed clear non-application of mind and hence were set aside. (SJ) (AY. 2015-16)