S. 148: Reassessment]-Notice-Notice issued in the name of dissolved firm-No notice has been issued to any of the partners-Non existing entity-Notice issued in the name and address of the non-existing entity is in violation of S. 283(2), and it has no sanctity in the eyes of the law-Assessment order was quashed. [S.144B, 147, 189, 283(2)]
Held that since the notice under s. 148 has not been issued to the partners of the assessee firm immediately before its dissolution in compliance with the provisions of S. 283(2); the assessment framed based on such notice is quashed. Followed: Nathalal Hemabhai Patel v. ITO (2024) 167 taxmann.com 337 (Guj) (HC). (AY. 2013-14, 2014-15)
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