Entire Reopening Invalid Due to Lack of Proof of Section 148 Notice Service: ITAT Delhi

Sangeeta Sharma Vs ITO (ITAT Delhi) Reassessment Quashed for Non-Service of 148 Notice – Entire Proceedings Held Void Ab Initio The Delhi ITAT allowed the assessee’s appeal and quashed the entire reassessment for AY 2013-14 on the ground that the mandatory notice under Section 148 was never validly served upon the assessee. The Tribunal noted that although the Department claimed to have issued the notice at the assessee’s residential address, no acknowledgement or any evidence of service was produced before the Bench. The Revenue also failed to demonstrate compliance with the mandatory r...