Individual service of notice was required for reassessment extension; website publication could not replace statutory service.

Individual service of notice is a condition precedent before extending the reassessment period under the Punjab Value Added Tax Act and Rules. The prescribed modes of service are hand delivery, registered post, or e-mail, and a general website publication is not a valid substitute. Because no individual notice was served before the extension order, the statutory requirement of service and the opportunity of hearing were not met, rendering the extension order unsustainable and the reassessment proceedings without jurisdiction.

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Issues: Whether service of a notice by uploading it on the department's website was a valid mode of service for extending the period for reassessment under the Punjab Value Added Tax Act, 2005 and the Punjab Value Added Tax Rules, 2005, or whether individual service of notice was mandatory.

Analysis: Section 29(3) empowers reassessment and section 29(4) permits such reassessment within three years, with a further extension up to six years only where the statutory requirements are satisfied. The proviso to section 29(4) could be invoked only after affording the affected dealer an opportunity of hearing. Rule 86 prescribes the modes of service of notice by hand, registered post or e-mail, and does not contemplate a general notice or publication on the department's website. Since no individual notice was served on the assessees before the extension order, the statutory requirement of service was not met. The absence of valid service meant that the extension order could not sustain the reassessment proceedings.

Conclusion: Individual service of notice was mandatory, and website publication was not a valid substitute. The reassessment orders were therefore without jurisdiction and void, and the appeal failed.

Ratio Decidendi: Where the statute and rules prescribe specific modes of service and the power to extend limitation affects the rights of the assessee, individual notice and an opportunity of hearing are a condition precedent to valid exercise of that power.

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