Delivery of notice u/s 148 at correct address of assessee is foundation for initiation of reassessment proceedings – ITAT

Brief of the Case:  ITAT Delhi held In the case of ITO vs. Hepta Developers Pvt. Limited that notice u/s 148 is foundation of the reassessment proceeding. The notice was sent on wrong address while the correct address was available in the return filed by the assessee. As the notice not served upon the assessee, this makes the whole proceedings as void – ab- initio. Under the circumstances, the action of the AO of making Best Judgement assessment u/s 144, in respect of which evidently no material was gathered by the AO, is not sustainable. Facts of the Case:  The assessee filed return of in...