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    <title>2026 (4) TMI 197 - ORISSA HIGH COURT</title>
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    <description>Reassessment under the Income-tax Act was held unsustainable where the Section 148 notice was issued within limitation under Section 149, but service of that notice on the assessee before completion of assessment was not established. The court treated the defect as a violation of the statutory requirement of prior service and natural justice, while noting that the Assessing Officer did not lack subject-matter jurisdiction because the notice itself was timely issued. The assessment order and consequential demand notice were set aside, and the matter was remanded for fresh assessment after service of notice and an opportunity of hearing.</description>
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      <description>Reassessment under the Income-tax Act was held unsustainable where the Section 148 notice was issued within limitation under Section 149, but service of that notice on the assessee before completion of assessment was not established. The court treated the defect as a violation of the statutory requirement of prior service and natural justice, while noting that the Assessing Officer did not lack subject-matter jurisdiction because the notice itself was timely issued. The assessment order and consequential demand notice were set aside, and the matter was remanded for fresh assessment after service of notice and an opportunity of hearing.</description>
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