Allahabad HC Invalidates Notice u/s. 148A(b) for Service to Unregistered Email ID

Grs Hotel Pvt. Ltd. Vs Union Of India (Allahabad High Court)

Allahabad High Court held that valid service of notice under section 148 of the Income Tax Act is a condition precedent for making reassessment under section 147. Accordingly, non-service of notice on registered email ID is unsustainable in the eyes of law.

Facts-

The petitioner is a private limited company engaged in the business of developing and Managing hotels, motels, resorts, restaurants, cafes and other similar activities.

A notice u/s. 148A(b) dated 07.03.2023 had been issued by the income tax department to the petitioner on the ground that there had been a heavy financial transaction for the sale/purchase of a property amounting to Rs. 6,31,10,000/- as per section 56(2)(x) of the Income Tax Act.

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