Invalid service of reassessment notice at an old email address deprived the tax authority of jurisdiction.

Service of a section 148 notice at an assessee's old email address, after the email was updated in later return filings, was held not to be valid service. Because the notice was sent to the email used by the earlier chartered accountant and not to the updated address, the defect went to the root of the reassessment proceedings. Applying the jurisdictional High Court precedent relied upon, the invalid service deprived the Assessing Officer of jurisdiction, and the reassessment order was void.

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Issues: Whether reassessment proceedings were without jurisdiction because the notice under section 148 was sent to an old email address and was not validly served on the assessee.

Analysis: The notice under section 148 was issued to the email ID used by the assessee's earlier chartered accountant, whereas the assessee had already updated his email address in later return filings before the notice was issued. On the facts, service at the old email ID did not constitute valid service. Following the jurisdictional High Court precedent relied upon, the defect went to the root of the reassessment proceedings and deprived the Assessing Officer of jurisdiction.

Conclusion: The reassessment notice was invalidly served and the reassessment order was void for want of jurisdiction.

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