Held, allowing the petition, that the show-cause notices issued under section 148A(b) to the amalgamating entities SIPL and SRPL were non est in law. The solitary ground for reassessment under section 147 was based on the premise that the assessee had not filed its return of income for the assessment year 2016-17. The assessee had duly intimated the Department about the amalgamation and that the corporate entities SIPL and SRPL did not exist. It had also stated that it had never entered into any sale transaction with SH and the sale transaction undertaken by the amalgamating entity, which was the solitary rationale for issuance of the show-cause notice under section 148A(b) had also been rightly shown in its return of income. No return of income could have been filed on behalf of the amalgamated entity as such entity was non est in law. The assessee in its return had also declared the income earned by the amalgamating entity SRPL. The Assessing Officer neither before issuing the show-cause notice under section 148A(b) nor before passing the order under section 148A(d) had considered the assessee’s return of income filed which had duly captured the income earned by the amalgamated entity. Therefore, the initial notice was issued without due application of mind and in a mechanical manner, without adhering to the statutory responsibilities envisaged under section 148. The matter need not be remitted to the Assessing Officer since the reason for the issuance of the notice under section 148A(b) was itself de hors the available record. The show-cause notice under section 148A(b) and the order passed under section 148A(d) were set aside. The Department was given liberty to take appropriate fresh action, if permissible in law on any other count.(AY. 2016-17)