2026 (1) TMI 1263

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....e petitioner' income for the assessment year 2017-18 have been initiated. 2. The petitioner no. 1 (hereafter "the petitioner") was initially issued a notice dated March 8, 2024 under Section 148A(b) of the said Act of 1961 calling upon the petitioner to show cause as to why should the petitioner's case not be reopened and the petitioner's income for the assessment year 2017- 2018 be not reassessed on the ground of escapement thereof from assessment. 3. The petitioner did not reply to the said notice to show cause and as such, an order under Section 148A(d) of the said Act of 1961 came to be passed. The order was followed by a reopening notice under Section 148 of the said Act of 1961 issued on April 8, 2024. Assailing the said notice ....

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....invites the attention of this Court to Rule 127 of the Income Tax Rules, 1962 as well as a Notification dated September 12, 2019 issued by the Ministry of Finance, Department of Revenue (Central Board of Direct Taxes) and submits that service of notices and orders by uploading thereof on the portal is valid mode of service and the petitioner ought to have been vigilant enough to take note of the same. It is further submitted that since service through the portal has already been done, non-service of the notices and the order impugned through the changed email ID of the petitioner should not vitiate the proceedings. 7. Heard learned advocates appearing for the respective parties and considered the material on record. 8. Mr. Bhattachary....