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    <title>2025 (3) TMI 1010 - DELHI HIGH COURT</title>
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    <description>Reassessment proceedings were set aside where service of the notice under section 148A(b), the order under section 148A(d), and the notice under section 148 was not established at the assessee&#039;s registered office in Singapore. As the assessee&#039;s lack of PAN and IT portal access was not contradicted, the Court held that the assessee had not effectively received the notice to respond and declined to examine the merits of whether the receipts were FTS/FIS or covered by the DTAA. The matter was restored to the stage of consideration of the section 148A(b) notice, with liberty to file a substantive reply.</description>
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      <description>Reassessment proceedings were set aside where service of the notice under section 148A(b), the order under section 148A(d), and the notice under section 148 was not established at the assessee&#039;s registered office in Singapore. As the assessee&#039;s lack of PAN and IT portal access was not contradicted, the Court held that the assessee had not effectively received the notice to respond and declined to examine the merits of whether the receipts were FTS/FIS or covered by the DTAA. The matter was restored to the stage of consideration of the section 148A(b) notice, with liberty to file a substantive reply.</description>
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