Notice issued u/s 148 of Income Tax

[vishwanath shetty]

A notice u/s 148 was issued as the assessee had not filed the ITR but there was purchase of property in SFT-12. Before this notice no other notice or SCN was issue.

After notice u/s 148, notice u/s 142(1) and SCN u/s 144 was also issued. Since the email and phone no mentioned on the portal were discontinued a long time ago. Assesse was not aware of any of this notices. After receiving a hardcopy for penalty proceedings all the facts regarding, previous notice came to light.

I am not sure is the notice issued u/s 148 valid as no SCN u/s 148A was issued prior to it. Should we proceed with filing of appeal, giving all the classification of investment of property or fight that the notice is invalid?

AI Summary

Reassessment notice validity without section 148A procedure where property purchase information triggered proceedings and prior notices were missed. Validity of a reassessment notice issued under section 148 where the assessee had not filed a return and the department relied on purchase of property reflected in SFT-12. The notice was issued without any prior notice or show-cause notice under section 148A, and subsequent notices under section 142(1) and section 144 were also issued. The issue raised is whether the reassessment notice is valid in the absence of prior section 148A procedure.