Service of reassessment notice is a factual issue; no substantial question of law arose and the Revenue succeeded.

Service of reassessment notice under Section 148 was treated as a question of fact, not a substantial question of law. The Tribunal found that the notices were served on 31.03.2003 and that the reassessment orders were time-barred. The High Court held that no illegality was shown in that finding and that the appeal did not raise any substantial question of law for consideration. The appeal was therefore dismissed for lack of merit, with the Revenue succeeding.

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Issues: Whether the appeal raised any substantial question of law in relation to service of notice issued for reassessment under Section 148 of the Income-tax Act, 1961.

Analysis: The dispute centered on the date on which the reassessment notices were served. The Tribunal had recorded a finding that the notices were served on 31.03.2003 and that the reassessment orders were time-barred. The High Court held that the question of service of notice was a question of fact and that no illegality was shown in the Tribunal's order. It further held that no substantial question of law arose for consideration.

Conclusion: The appeal was dismissed as lacking merit, in favour of the Revenue.

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