https://www.taxtmi.com/caselaws?id=385597 Service of notice under section 148 was treated as a jurisdictional prerequisite for reassessment under section 147. Where the assessee denied receipt, the Department had to prove valid service with cogent material. Affixture was held insufficient because the requirements for substituted service under Order V Rules 17, 19 and 20 CPC were not met: there was no proper basis for affixture, the report lacked necessary particulars, and verification on oath was not shown. Service by speed post was also unproved because supporting postal evidence was absent. Presumptions under section 27 of the General Clauses Act and section 114 of the Evidence Act did not apply on the facts, and the reassessment was invalid for want of proper service. en-us Fri, 22 Mar 2019 00:00:00 +0530 Mon, 09 Sep 2019 17:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=385597 Service of notice under section 148 was treated as a jurisdictional prerequisite for reassessment under section 147. Where the assessee denied receipt, the Department had to prove valid service with cogent material. Affixture was held insufficient because the requirements for substituted service under Order V Rules 17, 19 and 20 CPC were not met: there was no proper basis for affixture, the report lacked necessary particulars, and verification on oath was not shown. Service by speed post was also unproved because supporting postal evidence was absent. Presumptions under section 27 of the General Clauses Act and section 114 of the Evidence Act did not apply on the facts, and the reassessment was invalid for want of proper service. Case-Laws Income Tax Fri, 22 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=385597