2025 (5) TMI 1073
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....M. R. Sahu, AR. For The Respondent : Shri Prathvi Raj Meena, CIT. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: This appeal was originally decided vide order ITA No. 68/Ahd/2023 dated 20.05.2024 and the appeal of the assessee was dismissed. Thereafter, the assessee had filed a Miscellaneous Application on the ground that additional legal ground taken by the assessee were omitted to be adjudic....
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....by the assessee on this email address. He further submitted that the intimation sent by the department on any other email address was not a valid service of notice. 3. Per contra, Shri Prathvi Raj Meena, Ld. CIT.DR submitted that before processing return of income, a notice of adjustment u/s. 143(1)(a) of the Act was issued to the assessee on 23.03.2019, which was sent on the assessee's email add....
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....tted that identical issue was involved in assessee's own case in A.Y. 2019- 20 reported in Checkmate Services (P) Ltd, vs. ADIT, CPC (164 taxmann.com 498) and the ITAT had held that the email address "[email protected]" belonged to the assessee and that a notice sent on this email address was valid communication. 4. We have considered the rival submissions. The contention of the ass....
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....t intimation u/s. 143(1) of the Act sent to the assessee on this email address was duly received by the assessee, it cannot take a plea that the earlier notice for adjustment sent on this email address was not received. A copy of the notice dated 23.03.2019 for the proposed adjustment u/s 143(1)(a) of the Act has also been brought on record by the Revenue. Therefore, the contention of the assessee....