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The HC held that the reassessment proceedings were invalid due to non-service of proper notice under Section 148, as the initial notice was sent to an incorrect email ID. The petitioner only became aware of the proceedings upon receipt of a notice sent to the correct email on 18.10.2022, a fact not disputed by the DR. The court emphasized the principle of audi alteram partem, requiring fair hearing through proper notice to ensure an unbiased process. Since the petitioner was deprived of the opportunity to contest the reassessment due to defective service of notice, the appeal was allowed, rendering the reassessment proceedings void ab initio.
The HC held that the reassessment proceedings were invalid due to non-service of proper notice under Section 148, as the initial notice was sent to an incorrect email ID. The petitioner only became aware of the proceedings upon receipt of a notice sent to the correct email on 18.10.2022, a fact not disputed by the DR. The court emphasized the principle of audi alteram partem, requiring fair hearing through proper notice to ensure an unbiased process. Since the petitioner was deprived of the opportunity to contest the reassessment due to defective service of notice, the appeal was allowed, rendering the reassessment proceedings void ab initio.
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