Reassessment orders annulled for failure to prove notice. Appeals allowed, orders declared invalid.

The Tribunal annulled the reassessment orders and the CIT(A) order for all assessment years due to the failure to prove service of notice under section 148, a mandatory requirement for valid reassessment proceedings. The appeals were allowed, and reassessment orders were declared invalid.

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Issues Involved:
1. Validity of notice under section 147 read with section 148 of the Income-tax Act.
2. Compliance with the directions of the Income-tax Appellate Tribunal (ITAT).
3. Verification of service of notice.
4. Legality and jurisdiction of reassessment proceedings.
5. Limitation period for reassessment.
6. Opportunity of hearing and principles of natural justice.
7. Merits of additions and disallowances in ex-parte assessment.

Issue-wise Detailed Analysis:

1. Validity of Notice Under Section 147/148:
The primary contention was that the notices under section 147/148 were not validly served on the assessee. The report from the Income Tax Officer (ITO) indicated that notices were issued but did not provide evidence of service. The Tribunal emphasized that service of notice is a condition precedent for reassessment proceedings, citing the Hon'ble Jurisdictional High Court's decision in CIT v. Mintu Kalita, which held that mere issuance of notice is insufficient without proof of service.

2. Compliance with ITAT Directions:
The ITAT had previously remanded the case to the CIT(A) with specific directions to verify the service of notice and examine whether there was another individual with a similar name in the locality. The CIT(A) failed to comply with these directions adequately, as the necessary verifications and inquiries were not conducted properly.

3. Verification of Service of Notice:
The CIT(A) sought verification from the postal authorities, who responded that the case was time-barred and records could not be furnished. Additionally, the assessee provided an affidavit stating the existence of another individual with a similar name. The ITO's report did not conclusively establish the service of notice, leading to the Tribunal's conclusion that there was no concrete evidence of service.

4. Legality and Jurisdiction of Reassessment Proceedings:
The Tribunal reiterated that the AO's jurisdiction to initiate reassessment proceedings is contingent upon the proper service of notice under section 148. Given the lack of evidence for service, the reassessment proceedings were deemed illegal and without jurisdiction.

5. Limitation Period for Reassessment:
The Tribunal addressed the issue of limitation, noting that the notices were issued within the period of limitation. However, the service of notice, which is a condition precedent for reassessment, was not established, rendering the proceedings invalid despite the notices being issued in time.

6. Opportunity of Hearing and Principles of Natural Justice:
The assessee argued that the ex-parte assessment was made without affording a reasonable opportunity of hearing. The Tribunal found that the AO completed the assessments ex-parte due to non-compliance by the assessee, but this was moot since the reassessment proceedings themselves were invalid due to lack of proper notice service.

7. Merits of Additions and Disallowances in Ex-Parte Assessment:
The Tribunal did not delve into the merits of the additions and disallowances made in the ex-parte assessment, as the entire reassessment proceedings were annulled due to the foundational issue of improper notice service.

Conclusion:
The Tribunal annulled the reassessment orders and the impugned order of the CIT(A) for all the assessment years under consideration due to the failure to prove the service of notice under section 148, which is a mandatory requirement for valid reassessment proceedings. The appeals were allowed, and the reassessment orders were declared invalid.

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