Valid substituted service is essential for reassessment; failure to prove service within limitation vitiates jurisdiction.

Strict compliance with substituted service requirements is mandatory for reassessment notices under the Income-tax Act. The notice under section 148 was found unsupported by consistent documentary proof, and the Inspector's report did not identify the persons or witnesses associated with affixture, so service by affixture was not proved in accordance with law. Because the earliest effective communication was only in 2015, initiation of reassessment was treated as beyond the permissible time under sections 148 and 149. The reassessment notice was therefore invalid, jurisdiction failed, and the assessment was quashed.

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Issues: Whether the reassessment proceedings were invalid for want of proper service of notice under section 148; and whether the assessment could survive when the initiation of proceedings was beyond the prescribed time and the service by affixture was not shown to have been made in accordance with law.

Analysis: The notice said to have been issued in 2013 was not supported by consistent documentary proof, and the postal record produced did not match the Assessing Officer's version. The report of the Income Tax Inspector also did not disclose the names of neighbours or any responsible person who identified the premises, nor the person in whose presence the notice was affixed. Section 282 of the Income-tax Act, 1961 permits service in the manner provided under the Code of Civil Procedure, which requires due diligence before resorting to affixture and a proper report explaining the circumstances and identifying witnesses. In the absence of such compliance, the service could not be treated as valid. As the earliest effective communication was only in 2015, the initiation of proceedings was held to be beyond the permissible time under sections 148 and 149.

Conclusion: The reassessment notice was held to be invalid, the assumption of jurisdiction failed, and the assessment was quashed in favour of the assessee.

Final Conclusion: The assessment and the appellate order were set aside because the reopening itself was vitiated by invalid service of notice and consequent lack of jurisdiction.

Ratio Decidendi: Where reassessment is initiated on the basis of substituted service, strict compliance with the statutory mode of service is mandatory, and failure to establish valid service within limitation renders the reassessment proceedings void.

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