Invalid service by affixture vitiates reassessment where mandatory substituted-service procedure is not followed.

Service of a reassessment notice by affixture was invalid where the notice date was inconsistent with the asserted issue and service dates, and the affixture report did not comply with the mandatory requirements for substituted service. The record lacked association of two independent local witnesses and reliable identification of the premises. As service was not effected in the prescribed manner, the notice under section 148 was held invalid and the reassessment framed on that basis was quashed as void ab initio.

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Issues: Whether the reassessment was valid when notice under section 148 was alleged to have been served by affixture without compliance with the procedure prescribed for such service.

Analysis: The notice carried a date that was inconsistent with the dates asserted for its issue and service. The affixture report did not show association of two independent local witnesses or any reliable identification of the premises in the manner required for substituted service. In the absence of compliance with the mandatory procedure for affixture, the service of notice was held to be invalid.

Conclusion: The notice under section 148 was invalidly served and the reassessment framed on that basis was quashed as void ab initio.

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