https://www.taxtmi.com/caselaws?id=770329 ITAT Mumbai quashed reassessment proceedings initiated under section 147 due to invalid service of notice under section 148. The AO served notice on a tax consultant without establishing their authorization to receive notices on behalf of the assessee. Despite conducting survey at assessee's PE premises (Aptivaa India), revenue failed to serve notice at correct address or demonstrate the served address belonged to assessee. The tribunal held that improper notice service invalidated the entire reassessment, as valid notice under section 148 forms the foundation of reassessment proceedings under the old regime. en-us Tue, 15 Apr 2025 00:00:00 +0530 Fri, 20 Feb 2026 17:41:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770329 ITAT Mumbai quashed reassessment proceedings initiated under section 147 due to invalid service of notice under section 148. The AO served notice on a tax consultant without establishing their authorization to receive notices on behalf of the assessee. Despite conducting survey at assessee's PE premises (Aptivaa India), revenue failed to serve notice at correct address or demonstrate the served address belonged to assessee. The tribunal held that improper notice service invalidated the entire reassessment, as valid notice under section 148 forms the foundation of reassessment proceedings under the old regime. Case-Laws Income Tax Tue, 15 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770329