Sec. 179 of the Income-tax Act, 1961 – Company in liquidation – 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, while quashing the impugned order, one opportunity is given 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 –  ASHITA NILESH PATEL [2020] 270 TAXMAN 132 (GUJ)