Valid service of reassessment notice is mandatory; portal-only uploading was held insufficient, quashing reopening.

Reassessment under sections 147/148 depends on valid service of notice, and portal-only uploading was found insufficient on the facts because the notices were neither sent to the registered e-mail address nor by post. The Tribunal treated this as invalid service and held that reopening could not proceed on that basis, so the reassessment was quashed.

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Issues: Whether reassessment proceedings initiated under section 147/148 were valid where the notices were uploaded only on the portal and were not otherwise served on the assessee.

Analysis: The challenge to reopening turned on service of notice. The assessee's case was that the notices were placed only on the ITBA portal and were neither sent to the registered e-mail address nor by post. The Tribunal accepted that portal-only uploading, on the facts presented, did not constitute valid service and treated the reopening as covered by the governing principle that reassessment cannot proceed on an invalid notice.

Conclusion: The reassessment proceedings under section 147/148 were quashed and the reopening was held invalid.

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