Notice mailed to email Address not belonging to Assessee Not Amounts to Proper Service

Barua and Company Pvt. Ltd. Vs. Union Of India & Ors. (Meghalaya High Court) The affidavit-in-reply filed by the assessee has robustly denied that the relevant email address to which the three notices of April, 2022 were issued belonged to the assesse or that such address had been furnished by any authorised officer of the assesse. It is apparent that the Department has failed to discharge the burden of proving that the notices for hearing had been served on the assessee for the assessee to be penalised for not availing of the opportunity of hearing. As a consequence, it follows that the o...