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    <title>2018 (4) TMI 1277 - ITAT HYDERABAD</title>
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    <description>Strict compliance with substituted service requirements is mandatory for reassessment notices under the Income-tax Act. The notice under section 148 was found unsupported by consistent documentary proof, and the Inspector&#039;s report did not identify the persons or witnesses associated with affixture, so service by affixture was not proved in accordance with law. Because the earliest effective communication was only in 2015, initiation of reassessment was treated as beyond the permissible time under sections 148 and 149. The reassessment notice was therefore invalid, jurisdiction failed, and the assessment was quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=359166</link>
      <description>Strict compliance with substituted service requirements is mandatory for reassessment notices under the Income-tax Act. The notice under section 148 was found unsupported by consistent documentary proof, and the Inspector&#039;s report did not identify the persons or witnesses associated with affixture, so service by affixture was not proved in accordance with law. Because the earliest effective communication was only in 2015, initiation of reassessment was treated as beyond the permissible time under sections 148 and 149. The reassessment notice was therefore invalid, jurisdiction failed, and the assessment was quashed.</description>
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