Dismissing the petition the Court held that the notice under section 148 of the Income-tax Act, 1961, was also sent to the e-mail address of the assessee on April 12, 2022 and the same had been received, which was admitted by the petitioner. A perusal of the show-cause notice would reveal that in spite of having cash deposits in the bank and in spite of tax having been deducted at source under section 194C of the Act, the assessee failed to file returns of income for the year under consideration. Further, the assessee was given an opportunity for a hearing by issuing a show-cause notice under section 148A(b) of the Act, calling upon the assessee to submit necessary evidence in support of his claim. This was challenged mainly on the ground that the authorities could not have issued a notice to a firm, which was dissolved in the year 2001 itself and secondly that before issuing notice, an opportunity should have been given to the assessee to submit its explanation. The records showed that the bank account with the old permanent account number of the firm which had been allegedly dissolved was being operated in the bank. The amount in the bank account was said to be around Rs. 10 crores, in respect of which tax was also deducted at source under section 194C. That being the position, it was not proper to say that the authorities erred in issuing the notice. The notice and consequent proceedings were valid. (AY.2015-16)