Allowing the petition, the Court held that, participation in the proceedings would not operate as an estoppel against law, based upon the settled legal principle that the amalgamating entity had ceased to exist upon the scheme of amalgamation being approved. Accordingly, when a company was amalgamated with petitioner company by an approved scheme of amalgamation, and such factum was communicated to concerned income-tax authorities, order passed under section 148A(d) and subsequent issue of notice under section 148 against such amalgamating company which ceased to exist. Oreder was quashed. Referred Saraswati Industrial Syndicate Ltd. v. CIT [1990] 53 Taxman 92/186 ITR 278 (SC), Spice Entertainment Ltd. v. CST 2012 (280) ELT 43 (Delhi) (HC) and Pr. CIT v. Maruti Suzuki India Ltd. (2019) 107 taxmann.com 375/ 265 Taxman 515/ 416 ITR 613(SC) (AY. 2013-14)