Issue of Section 148 notice on non-existing entity is not a curable mistake

Implenia Services and Solutions Pvt. Ltd. Vs DCIT (Bombay High Court) It is admitted that notice has been issued to a non existing entity but respondents state that it ought to be treated as a mistake and the name given in the notice could be corrected under Section 292B of the Income Tax Act, 1961. High Court held that Where notice under section 148 was issued to a non-existing entity as said entity ceased to exist at the time of the issue of the notice on account of merger; the said notice was liable to be quashed and it was not an error that could be corrected under section 292B. FULL TEXT ...