Validity of reassessment notice service and Section 282 compliance examined in income-tax proceedings

Service of notice under Section 148 of the Income-tax Act is examined in relation to the address used for dispatch, where the department relied on an address obtained from the bank rather than the address shown in the return. The note also addresses whether reassessment proceedings can continue without proper service in accordance with Section 282. The recorded outcome is that notice was issued and operation of the impugned order was stayed until further orders.

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Issues: (i) Whether service of notice under Section 148 of the Income-tax Act, 1961 on the address collected by the department from the bank, instead of the address shown in the return, could be treated as valid; (ii) whether proceedings initiated pursuant to notice under Section 148 could continue without proper service in accordance with Section 282 of the Income-tax Act, 1961.

Outcome: Notice issued and the operation of the impugned order stayed until further orders.

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