https://www.taxtmi.com/caselaws?id=406773 Reassessment under section 147 could not be sustained without prior valid service of notice under section 148, because service is a jurisdictional for assumption of reassessment powers. The revenue failed to prove due service: the address in the assessment record was incorrect, affixture at the last known address was not supported by reliable material, and electronic service was rejected because no valid e-mail address sourced in the manner required by section 282 read with rule 127 was shown. As the correct address was available from the return, PAN database and bank records but was not used, the reassessment was held invalid and the assessment was quashed; the merits of the additions were left open. en-us Tue, 30 Mar 2021 00:00:00 +0530 Fri, 23 Apr 2021 21:03:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=406773 Reassessment under section 147 could not be sustained without prior valid service of notice under section 148, because service is a jurisdictional for assumption of reassessment powers. The revenue failed to prove due service: the address in the assessment record was incorrect, affixture at the last known address was not supported by reliable material, and electronic service was rejected because no valid e-mail address sourced in the manner required by section 282 read with rule 127 was shown. As the correct address was available from the return, PAN database and bank records but was not used, the reassessment was held invalid and the assessment was quashed; the merits of the additions were left open. Case-Laws Income Tax Tue, 30 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=406773