Improper service in reassessment proceedings led to quashing of section 148A(d) and section 148 notices, with remand for fresh reply.

Reassessment proceedings were set aside where service of the notice under section 148A(b), the order under section 148A(d), and the notice under section 148 was not established at the assessee's registered office in Singapore. As the assessee's lack of PAN and IT portal access was not contradicted, the Court held that the assessee had not effectively received the notice to respond and declined to examine the merits of whether the receipts were FTS/FIS or covered by the DTAA. The matter was restored to the stage of consideration of the section 148A(b) notice, with liberty to file a substantive reply.

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Issues: Whether the reassessment notice under section 148A(b), the order under section 148A(d), and the notice under section 148 were liable to be quashed for want of proper service and breach of natural justice, and whether the matter should be remitted to the stage of consideration under section 148A(b).

Analysis: The record did not establish service of the impugned notices and order at the assessee's registered office in Singapore. The assessee's position that it had no PAN or IT portal credentials was not contradicted. In these circumstances, the Court declined to enter into the merits of whether the receipts constituted FTS/FIS or were covered by the DTAA, because the assessee had not effectively received the notice calling for a response. The Court therefore found it appropriate to restore the matter to the stage where a proper reply to the notice under section 148A(b) could be filed and considered by the Assessing Officer.

Conclusion: The impugned order under section 148A(d) and the impugned notice under section 148 were quashed, and the matter was remitted to the stage of consideration of the notice under section 148A(b), with liberty to the assessee to file a substantive reply.

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