Reassessment proceedings u/s. 147 cannot be sustained in absence of valid service of notice

Mahesh Gautam Vs CIT (Allahabad High Court)

Allahabad High Court held that in absence of valid service of notice under section 148 of the Income Tax Act, proceedings under section 147 of the Income Tax Act for reassessment cannot be initiated. Accordingly, appeal of the assessee allowed.

Facts- Based on the information received from the Central Excise Department, AO issued notice u/s. 148 of the Income Tax Act for A.Y. 2001-02, 2002-03 and 2003-04. These notices were sent via speed post to appellant’s address, but no return was filed by the appellant.<

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