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    <title>2026 (3) TMI 697 - ITAT DELHI</title>
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    <description>Whether reassessment under the Income-tax Act could be validly initiated where a preliminary notice and subsequent statutory notices were only uploaded on the Departmental e proceedings portal was decided by the Tribunal. The Tribunal applied the principle that valid service or demonstrable electronic transmission is a jurisdictional requirement for reopening; mere upload without evidence of transmission or of the date of first viewing does not establish effective communication. Finding no proof that the notices were transmitted or viewed so as to fix issuance for limitation purposes, the Tribunal concluded the reopening was vitiated and quashed the reassessment.</description>
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      <link>https://www.taxtmi.com/caselaws?id=787942</link>
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