https://www.taxtmi.com/caselaws?id=16180 HC allowed the appeal, holding that notices issued u/s 148 and 139(2), leading to reassessment u/s 147, were not validly served. The registered envelopes bore no endorsement indicating refusal, absence, or any attempt at actual tender of notice, and the Revenue's own consistent case was that service by registered post had failed, necessitating affixation. In absence of proof of valid service, the mandatory precondition for invoking jurisdiction u/s 147 was not satisfied, rendering the reassessment orders void. Consequently, proceedings initiated u/s 263, being founded on such invalid assessments, were without jurisdiction. The single judge's contrary findings were set aside and the writ appeal was allowed. en-us Fri, 28 Aug 1998 00:00:00 +0530 Wed, 17 Dec 2025 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=16180 HC allowed the appeal, holding that notices issued u/s 148 and 139(2), leading to reassessment u/s 147, were not validly served. The registered envelopes bore no endorsement indicating refusal, absence, or any attempt at actual tender of notice, and the Revenue's own consistent case was that service by registered post had failed, necessitating affixation. In absence of proof of valid service, the mandatory precondition for invoking jurisdiction u/s 147 was not satisfied, rendering the reassessment orders void. Consequently, proceedings initiated u/s 263, being founded on such invalid assessments, were without jurisdiction. The single judge's contrary findings were set aside and the writ appeal was allowed. Case-Laws Income Tax Fri, 28 Aug 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=16180