JUDGMENT

Manmohan, J. (Oral)

C.M.No.40737/2022 (exemption)

Allowed, subject to all just exceptions.

Accordingly, the application stands disposed of.

W.P.(C) No.13404/2022 & C.M.No.40705/2022

1. Present writ petition has been filed challenging the show cause notice dated 26th May, 2022 issued under Section 148A(b) of the Income Tax Act, 1961 [`the Act'] as well as the order passed under Section 148A(d) of the Act and the notice issued under Section 148 of the Act both dated 30th May, 2022 for the Assessment Year 2013-14.

2. Learned counsel for the petitioner submits that the impugned order and notice are void ab initio as they have been issued in the name of "Scilla Town Planners Pvt. Ltd." [`STPPL'], a non-existent entity as it had merged with the Petitioner-company vide order dated 5th May, 2014 of this Court with the appointed date of merger being 1st April, 2014.

3. He states that pursuant to the directions of the Supreme Court in Union of India v. Ashish Agarwal, 2022 SCC OnLine SC 543, the Petitioner was issued a letter dated 26th May, 2022 under Section 148A(b) of the Act alleging that STPPL had advanced a sum of Rs.15 Crore to M/s Wave One Pvt. Ltd. despite there bein