Reassessment notices and service of notice: Bombay HC quashes consequential action, but permits fresh service and objections.

Notices sent to the address on record with the Income-tax Department could not be faulted where the assessee had changed address without informing the Department or updating PAN details. On those facts, non-service was not attributable to the Revenue. However, the Court still quashed the order under Section 148A(d) and the consequential notices under Sections 148 and 142(1), and directed fresh service at the updated address and email-id furnished before it, so that objections to the Section 148A(b) notice could be filed and considered.

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Issues: Whether the reassessment order and subsequent notices could be sustained when the notices were not duly served, and what consequential relief should follow.

Analysis: The notices were issued to the address available with the Income-tax Department. The Petitioner had changed her address but had not informed the Department or updated the PAN details. In these circumstances, non-service could not be attributed to the Respondents. At the same time, the Court granted limited relief by quashing the order under Section 148A(d) and the consequential notices under Sections 148 and 142(1), while preserving the opportunity for the Petitioner to file objections to the Section 148A(b) notice after service at the updated address and email-id furnished before the Court.

Conclusion: The challenge succeeded in part, and the impugned order and consequential notices were quashed, with directions for fresh service and consideration of objections.

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