ITAT Delhi: No Proper Service of U/s 148 Notice – Entire Reassessment Quashed

Ranbir Singh Vs ITO (ITAT Delhi) In this case, the ITAT Delhi held that non-service of notice u/s 148 renders the entire reassessment invalid, irrespective of merits. The Tribunal found that: Notice u/s 148 was sent to the assessee’s old office address, where he had already retired, The AO attempted service by affixture at an incorrect address, without verifying current whereabouts, and There was no proper or valid service of notice, which is a mandatory requirement. The ITAT emphasized that: Issuance of notice is not enough – valid service is compulsory, The entire assessment was c...