Sec. 179 of the Income-tax Act, 1961 - Company in liquidation - The subject matter of challenge in the writ-application at the instance of the writ-applicant is an order passed under section 179 of the IT Act, 1961. Writ application disposed of holding that ”If the show-cause notice is silent including the impugned order, the void left behind in the two documents cannot be filled by way of an affidavit-in-reply. Ultimately, it is the subjective satisfaction of the authority concerned that is important and it should be reflected from the order itself based on some cogent materials. However, with a view to protect the interest of both, the writ applicant as well as Revenue, we are inclined to quash the impugned order and give one opportunity to the Revenue to initiate the proceedings afresh by issuance of fresh show-cause notice with all necessary details so that the writ-applicant can meet with the case of the Revenue“. - SONAL NIMISH PATEL V/s ASSTT. CIT - [2020] 270 TAXMAN 141 (GUJ)