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HC determined that typographical error in address on notice under s.148 of IT Act does not invalidate reassessment proceedings. Taxpayer's claim for India-Singapore DTAA exemption without filing proper income tax return prompted IT Department's notice. Though taxpayer later filed manual return on 02.03.2022, department issued speaking order without considering CBDT Circular 3/2016. Court set aside speaking order dated 18.03.2022 and remanded matter, directing authorities to provide taxpayer reasonable opportunity to present case in light of CBDT Circular 3/2016. Mere address error on notice to Verizon Services Singapore Pte Ltd. (incorrectly sent to Visteon Tax Office, Michigan) does not render proceedings invalid.
HC determined that typographical error in address on notice under s.148 of IT Act does not invalidate reassessment proceedings. Taxpayer's claim for India-Singapore DTAA exemption without filing proper income tax return prompted IT Department's notice. Though taxpayer later filed manual return on 02.03.2022, department issued speaking order without considering CBDT Circular 3/2016. Court set aside speaking order dated 18.03.2022 and remanded matter, directing authorities to provide taxpayer reasonable opportunity to present case in light of CBDT Circular 3/2016. Mere address error on notice to Verizon Services Singapore Pte Ltd. (incorrectly sent to Visteon Tax Office, Michigan) does not render proceedings invalid.
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