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ITAT held that the reassessment proceedings were invalid due to improper service of notice u/s 148. The AO failed to demonstrate valid notice service to the assessee, serving instead on a tax consultant without establishing authorized representation. The tribunal found no evidence confirming the notice was served at the correct address. Consequently, the entire reassessment proceedings were quashed as the fundamental procedural requirement of proper notice was not fulfilled, rendering the subsequent assessment proceedings legally unsustainable.
ITAT held that the reassessment proceedings were invalid due to improper service of notice u/s 148. The AO failed to demonstrate valid notice service to the assessee, serving instead on a tax consultant without establishing authorized representation. The tribunal found no evidence confirming the notice was served at the correct address. Consequently, the entire reassessment proceedings were quashed as the fundamental procedural requirement of proper notice was not fulfilled, rendering the subsequent assessment proceedings legally unsustainable.
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