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 under section 148 can be challenged for non-compliance with section 148A, while also substantiating property investment sources.
A reassessment notice under section 148 based on property purchase information may be challenged where the pre-notice procedure under section 148A was not followed. The assessee should verify the assessment records, notice history, DIN-based communications, and service details before relying on the jurisdictional objection. In parallel, the source of investment in the property should be substantiated with supporting evidence, and both jurisdictional and factual grounds should be raised together in appeal.