Effective notice in revision proceedings is mandatory; order under Section 263 quashed after notice went to the old address.

Revisional proceedings were vitiated where notice under Section 263 was sent to the assessee's old address despite prior intimation of change of registered office and filing of the relevant company form. The court found that the assessee was prevented by sufficient cause from participating because effective notice and opportunity of hearing were not afforded. The impugned revisional order was therefore quashed, and the Commissioner was directed to issue fresh notice at the current address and proceed afresh in accordance with law.

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Issues: Whether the reassessment and revision proceedings were liable to be set aside for want of effective notice and opportunity of hearing to the assessee, and whether the Commissioner's revisional order under Section 263 could stand when notice was sent to the old address despite intimation of change of registered office.

Analysis: The assessee had intimated the change of registered office to the assessing authority and had filed the relevant company form, yet the revisional notice was issued at the old address. In these circumstances, the assessee was found to have been prevented by sufficient cause from participating in the proceedings under Section 263. The absence of effective notice and opportunity justified interference with the impugned revisional order.

Conclusion: The order passed under Section 263 was quashed, and the Commissioner was directed to issue fresh notice to the assessee at its present address and proceed afresh in accordance with law.

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