https://www.taxtmi.com/caselaws?id=13086 Validity of reassessment under s.147 turned on whether a notice under s.148 was duly served despite the assessee's authorised representative appearing before the AO in response to a s.142(1) notice. The HC held that service of s.148 notice is a statutory condition precedent for valid initiation of reassessment proceedings; mere issuance is insufficient, and appearance pursuant to s.142(1) (enquiry before assessment) cannot be treated as notice or deemed knowledge of s.147 proceedings. As there was no material showing service of any s.148 notice or appearance pursuant to it, the reassessment lacked the requisite notice; the issue was decided in favour of the assessee. en-us Thu, 22 Feb 2001 00:00:00 +0530 Mon, 05 Jan 2026 20:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13086 Validity of reassessment under s.147 turned on whether a notice under s.148 was duly served despite the assessee's authorised representative appearing before the AO in response to a s.142(1) notice. The HC held that service of s.148 notice is a statutory condition precedent for valid initiation of reassessment proceedings; mere issuance is insufficient, and appearance pursuant to s.142(1) (enquiry before assessment) cannot be treated as notice or deemed knowledge of s.147 proceedings. As there was no material showing service of any s.148 notice or appearance pursuant to it, the reassessment lacked the requisite notice; the issue was decided in favour of the assessee. Case-Laws Income Tax Thu, 22 Feb 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13086