https://www.taxtmi.com/caselaws?id=65609 Issue of notice under section 148 may commence reassessment proceedings, but valid reassessment also requires service of that notice on the assessee before the order is made. The ITAT held that departmental records showing only dispatch by registered post did not prove service, as no acknowledgment or other material established receipt by the assessee. It treated service as a mandatory factual requirement, not a mere procedural irregularity, and rejected the argument that participation in other notices or conduct could amount to waiver. The reassessment orders were therefore invalid and unsustainable. en-us Fri, 27 Oct 1989 00:00:00 +0530 Wed, 16 Feb 2011 18:51:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65609 Issue of notice under section 148 may commence reassessment proceedings, but valid reassessment also requires service of that notice on the assessee before the order is made. The ITAT held that departmental records showing only dispatch by registered post did not prove service, as no acknowledgment or other material established receipt by the assessee. It treated service as a mandatory factual requirement, not a mere procedural irregularity, and rejected the argument that participation in other notices or conduct could amount to waiver. The reassessment orders were therefore invalid and unsustainable. Case-Laws Income Tax Fri, 27 Oct 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65609