Mere copy of notice given during reassessment proceedings will not meet mandatory requirement of issue & service of notice

Delhi High Court held In the case of Principal CIT vs. Atlanta Capital Pvt. Ltd. that the requirement of both the issuance and the service of such upon the Assessee for the purposes of Section 147 and 148 of the Act are mandatory ‘jurisdictional requirements’. The fact that the assessee was provided a copy of the notice during reassessment proceedings will not make any difference on account of mandatory requirement of issuance & service of notice u/s 148.

Facts of the Case

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