Section 147: Assessee cannot be put to mercies of careless, casual, arbitrary or whimsical exercise of power

Simar Kaur Vs ACIT (ITAT Chandigarh) It is seen that the assessee has consistently maintained its challenge that notice was not issued as it has not been served. The tax authorities have rejected the challenge holding that non-receipt is not equivalent to non-service. It is seen that though the challenge is recorded the wording in its rejection has been remained ambivalent as no specific finding is found to have been given holding that the notice was issued on a specific date. Nor is there any reference addressing the mode and manner of its issuance nor the fact that it was issued at the corre...