The assessee challenged initiation of reassessment proceedings under sections 148 and 148A after completion of the Corporate Insolvency Resolution Process (CIRP) and approval of the resolution plan by the NCLT contending that all past liabilities stood extinguished. The High Court held that although recovery proceedings in respect of past liabilities may not survive after approval of a resolution plan under section 31 of the Insolvency and Bankruptcy Code, initiation of reassessment proceedings is not barred in law. Based on information available with the Department indicating suspicious trading patterns involving shell entities, identical purchase and sale quantities, abnormal price variations and momentary trades suggestive of fraudulent transactions undertaken to evade tax, the authorities were justified in invoking section 148A proceedings. The Court observed that CIRP cannot be permitted to operate as a mechanism to shield misdeeds, misappropriation or illegal transactions intended for tax evasion. Reassessment at this stage was only for inquiry and verification and not for fastening immediate tax liability, and the Department could also proceed against responsible directors if illegality was established. Accordingly, initiation of proceedings under section 148A was held valid and the writ petition was dismissed.  Followed, Dishnet Wireless Ltd. v. Asstt. CIT (2022) 139 taxmann.com 493  (Mad)(HC). (AY. 2014-15 to 2016-17)