https://www.taxtmi.com/caselaws?id=469530 Disputed service of an assessment order can defeat a limitation dismissal where the assessee credibly pleads non-receipt through the prescribed modes and the record does not rebut delayed knowledge. Proper communication under Rule 127 of the Income-tax Rules is required, and portal service alone was not treated as sufficient on the facts noted. Where an ex parte assessment under section 144 is completed without effective participation, and the assessee is denied a reasonable opportunity at both assessment and appellate stages, the proper course is remand for fresh verification and de novo adjudication without expressing any view on the merits of the capital gains addition. en-us Fri, 07 Mar 2025 00:00:00 +0530 Sat, 20 Jun 2026 21:58:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469530 Disputed service of an assessment order can defeat a limitation dismissal where the assessee credibly pleads non-receipt through the prescribed modes and the record does not rebut delayed knowledge. Proper communication under Rule 127 of the Income-tax Rules is required, and portal service alone was not treated as sufficient on the facts noted. Where an ex parte assessment under section 144 is completed without effective participation, and the assessee is denied a reasonable opportunity at both assessment and appellate stages, the proper course is remand for fresh verification and de novo adjudication without expressing any view on the merits of the capital gains addition. Case-Laws Income Tax Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469530