Personal service of notice is essential to valid acquisition proceedings under Chapter XXA; Gazette publication alone is insufficient.

Chapter XXA acquisition proceedings required both Gazette publication under section 269D(1) and individual service of notice on the transferor, transferee and other interested persons under section 269D(2). The statutory scheme, read with the objection period under section 269E(1) and the jurisdictional challenge bar in section 269B(3), showed that personal service was an integral condition for valid initiation. Mere publication in the Official Gazette without service on the transferee did not complete commencement of the proceedings. On that basis, the acquisition proceedings were held invalid for want of timely notice, and the order of acquisition was quashed in favour of the assessee.

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Issues: Whether acquisition proceedings under Chapter XXA were invalid for want of service of individual notice on the transferee under section 269D(2) within the prescribed period, and whether the order of acquisition could stand on that basis.

Analysis: The statutory scheme required not only publication of notice in the Official Gazette under section 269D(1) but also service of individual notice on the transferor, transferee and other interested persons under section 269D(2). The time available for filing objections under section 269E(1) and the limitation on challenging jurisdiction under section 269B(3) showed that service of notice was an integral part of valid initiation. On a harmonious construction of the provisions, mere Gazette publication without personal service did not complete initiation of acquisition proceedings.

Conclusion: The acquisition proceedings were invalid for failure to serve proper notice on the transferee within the prescribed time, and the order of acquisition was quashed in favour of the assessee.

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