Validity of Sec. 148 Notice Hinges on Dispatch Date – Matter Remanded for Verification as per Suman Jeet Agarwal

Cognizance Constructions Private Limited Vs. ITO (ITAT Hyderabad) The key issue in this appeal relates to validity of notice u/s 148 &  its date of issuance, which determines whether reassessment is within limitation. Assessee argued that the notice was not validly served, as it was claimed to be sent via email to an incorrect/irrelevant email ID as well as by speed post, but Assessee never received it. Assessee further contended that actual service, dispatch details &  delivery status must be verified before treating the notice as validly issued. Tribunal referred to the landmark ju...