Valid service of reassessment notice is jurisdictional; reassessment fails where notice under section 148 is not duly served.

Reassessment under section 147 could not be sustained without prior valid service of notice under section 148, because service is a jurisdictional for assumption of reassessment powers. The revenue failed to prove due service: the address in the assessment record was incorrect, affixture at the last known address was not supported by reliable material, and electronic service was rejected because no valid e-mail address sourced in the manner required by section 282 read with rule 127 was shown. As the correct address was available from the return, PAN database and bank records but was not used, the reassessment was held invalid and the assessment was quashed; the merits of the additions were left open.

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Issues: Whether the reassessment framed under section 144 read with section 147 of the Income-tax Act, 1961 was valid when the notice under section 148 was not shown to have been duly served on the assessee.

Analysis: The assessment could be sustained only if a valid notice under section 148 had been served before assumption of jurisdiction for reassessment. The address used in the assessment records was found to be incorrect, and the revenue did not produce reliable material to prove valid service by affixture at the last known address. Service through electronic mode was also rejected, as the record did not show a valid e-mail address sourced in the manner prescribed by section 282 of the Income-tax Act, 1961 read with rule 127 of the Income Tax Rules, 1962. On the facts, the correct address was available from the assessee's earlier return, the PAN database, and bank records, yet the notice was not served there.

Conclusion: The reassessment was invalid for want of proper service of notice under section 148, and the assessment was quashed. The merits of the additions were left open.

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