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    <title>1998 (4) TMI 504 - ALLAHABAD HIGH COURT</title>
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    <description>Valid service of a notice under section 21 is a condition precedent to reassessment jurisdiction. Rule 77 permits affixation only when ordinary modes of service are not practicable, and that prerequisite was satisfied here because personal service had failed on more than one occasion and registered post had also proved ineffective. The assessing authority had therefore formed the necessary objective opinion before directing substituted service by affixation. The challenge that affixation was impermissible without a prior report back was rejected on these facts, and the reassessment proceedings were not vitiated for want of valid service.</description>
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      <title>1998 (4) TMI 504 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=159083</link>
      <description>Valid service of a notice under section 21 is a condition precedent to reassessment jurisdiction. Rule 77 permits affixation only when ordinary modes of service are not practicable, and that prerequisite was satisfied here because personal service had failed on more than one occasion and registered post had also proved ineffective. The assessing authority had therefore formed the necessary objective opinion before directing substituted service by affixation. The challenge that affixation was impermissible without a prior report back was rejected on these facts, and the reassessment proceedings were not vitiated for want of valid service.</description>
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