Proper Service of Notice Required for Reopening Tax Assessment Under ITA Section 148 and CPC Orders V & III.

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....Validity of Reopening of assessment - Service of notice under section 148 of the Act on the assessee is a jurisdictional requirement and must be mandatory complied with and it should be in accordance with section 282(1) of the Act read with Rule Order V Rule 12 CPC and Order III Rule 6 CPC. The onus on the Revenue to show that proper service of notice has been affected on the issue or agent duly empowered by him to accept the notices. - AT....