The HC held that, given admitted ex parte proceedings and documentary confirmation that service via email was not established due to non-communication by the taxpayer's chartered accountant and the AO's own note that the email could not be located, there remained a real doubt as to valid service of the Section 148B notice. Relying on analogous authority, the HC declined to allow the ex parte consequence to stand and granted the Petitioner one opportunity to be heard, directing the Petitioner to appear before Respondent No. 3 and furnish a substantive reply to the Section 148B notice within the time stipulated by the AO.
The HC held that, given admitted ex parte proceedings and documentary confirmation that service via email was not established due to non-communication by the taxpayer's chartered accountant and the AO's own note that the email could not be located, there remained a real doubt as to valid service of the Section 148B notice. Relying on analogous authority, the HC declined to allow the ex parte consequence to stand and granted the Petitioner one opportunity to be heard, directing the Petitioner to appear before Respondent No. 3 and furnish a substantive reply to the Section 148B notice within the time stipulated by the AO.
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