Valid service of reassessment notice after dissolution is jurisdictional; defective service voids reassessment and best-judgment assessment.

Valid service of a notice under section 148 was treated as the jurisdictional foundation for reassessment. Where the firm or association had been dissolved, section 283 required service only on a person who was a partner or member immediately before dissolution, or on an authorised representative. Service on Sukhdev Parshad was ineffective because his status as partner, member, or authorised agent on the relevant date was not established. Prior service in another year and a payment made by him did not prove continuing authority to receive notice. The reassessment and the consequent best-judgment assessments under section 144 were therefore without jurisdiction and void in law.

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Issues: Whether notice under section 148 of the Income-tax Act, 1961 was validly served on a person alleged to be connected with the assessee after dissolution of the firm or association, and whether the reassessment and best-judgment assessments made under section 144 were therefore without jurisdiction.

Analysis: Valid service of the reassessment notice was treated as the foundation of jurisdiction. On the facts found, the notice was served only on Sukhdev Parshad, whose status as partner, member, or authorised agent of the assessee on the relevant date was not established. Section 283 specifically governed service where a firm or association of persons had been dissolved, and such notice could be served only on a person who was a partner or member immediately before dissolution. The earlier service of a notice in another year and a payment made by Sukhdev Parshad did not prove continuing authority to receive notice under section 148. The statutory requirement of service was therefore not satisfied.

Conclusion: Service of notice under section 148 was invalid, the reassessment proceedings lacked jurisdiction, and the assessments under section 144 were void in law.

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