Section 148 Notice Invalid for Wrong Email & Address: ITAT Dehradun

Akhilesh Singhal Vs ITO (ITAT Dehradun)

Reassessment Quashed & Penalties Deleted – ITAT Dehradun Holds Notice u/s 148 Invalid for Wrong Email & Address

Assessee filed return declaring ₹22 lakh. AO reopened the case on 29.03.2021 u/s 147 & completed ex-parte assessment u/s 144 r.w.s 144B, adding ₹27.86 lakh as unexplained bank deposits u/s 69A. CIT(A) upheld the addition.

Before Tribunal, Assessee raised an additional legal ground that the notice u/s 148 was never served, as it was sent to an old postal address & wrong e-mail ID despite AO

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