“service of notice”

ReassessmentSection 148Section 1483,297 judgments

The decision most relied on for service of notice is Earthmoving Equipment Service Corporation v. DCIT 22(2), Mumbai (84 Taxmann.com 51), cited in 263 judgments on BharatTax.

Leading authorities on service of notice

Earthmoving Equipment Service Corporation v. DCIT 22(2), Mumbai

84 Taxmann.com 51 · 2017 · ITAT

263

citing judgments

A penalty levied under Section 271(1)(c) for concealment of income or furnishing inaccurate particulars cannot be deleted merely due to technical defects in the penalty notice, such as not ticking the specific default, if the assessee understood the charges.

CIT v. Laxman Das Khandelwal

417 ITR 325 · 2019 · Supreme Court

225

citing judgments

Issuance of a notice under Section 143(2) is a mandatory requirement for completing an assessment when a return is filed, including reassessment under Section 147/143(3). The complete absence of this notice renders the assessment invalid and is not curable by Section 292BB.

1. S. S. Gadgil v. Lal & Co.

53 ITR 231 · 1964 · Supreme Court

158

citing judgments

Income-tax assessment proceedings are administrative in nature, not civil disputes or judicial proceedings between contesting parties. Income-tax authorities act as administrative bodies to estimate income and assess tax, and the proper service of notice within the limitation period is foundational for reassessment jurisdiction.

Munjal BCU Centre of Innovation and Entrepreneurship v. CIT (Exemptions)

463 ITR 560 · 2024 · High Court

citing judgments

Service of notice through the ITBA portal is not a valid method of service under section 282(1) of the Income-tax Act, 1961, and Rule 127(1) of the Income-tax Rules, 1962. Consequently, matters where notice was deemed invalidly served via ITBA portal are remanded to the Assessing Officer for a de novo disposal to uphold principles of natural justice.

Narayana Chetty v. ITO

35 ITR 388 · 1959 · Supreme Court

citing judgments

A valid and properly served notice under section 148 (or old section 34) is a mandatory and jurisdictional prerequisite for initiating reassessment proceedings; its absence or invalidity renders the entire proceedings illegal and void ab initio. The validity of service hinges on adherence to prescribed modes, not merely the recipient's acknowledgment.

Mavis Satcom Ltd. v. Deputy CIT

337 ITR 389 · 2011 · High Court

citing judgments

The present case is cited as authority for the proposition that notices issued under Section 148 of the Income-tax Act, 1961, are valid even if they do not refer to the reasons recorded for initiating reassessment proceedings, provided the reasons are communicated to the assessee. Furthermore, the issue of jurisdiction under Section 124(3) and the validity of notice under Section 143(2) are also key areas addressed.

CIT v. Gitsons Engineering Co.

370 ITR 87 · 2015 · High Court

citing judgments

The issuance of a notice under Section 143(2) is mandatory, and its non-service or invalidity is not a curable procedural irregularity, rendering subsequent assessment proceedings void. Objections regarding non-service of notice, being a jurisdictional issue, can be raised for the first time before the Tribunal.

Banarsi Debi v. ITO

53 ITR 100 · 1964 · Supreme Court

citing judgments

For income-tax notices, particularly under Section 34(1) of the 1922 Act (corresponding to Sections 147/148 of the 1961 Act), there is no real distinction between the 'issue' and 'service' of a notice. The word 'issued' must be given a wider meaning, effectively encompassing 'served'.

Judgments citing service of notice

Salim, Panipat vs. ITO, Ward-4, Panipat

In the result, appeal of the Assessee is dismissed

ITA 5816/DEL/2024[2009-2010]Status: DisposedITAT Delhi30 Dec 2025AY 2009-2010

Bench: SHRI ANUBHAV SHARMA (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: NoneFor Respondent: Shri Manish Gupta, Sr. DR

Section 139Section 142(1)Section 144Section 148Section 271(1)(c)Section 274Section 69A

carefully considered the orders of the lower authorities. 8.1 At the outset, as regards the procedural grounds raised by the assessee alleging non service of notice and illegality of assessment framed under sections 144/147 of the Act, we find no merit in the same. The records clearly demonstrate that

Abishek Chandok, Delhi vs. Income Tax Officer, Delhi

In the result, impugned order is quashed and appeal of the assessee is allowed

ITA 7095/DEL/2025[2019-20]Status: DisposedITAT Delhi29 Dec 2025AY 2019-20

Bench: Shri Vikas Awasthyआअसं.7095/धिल्ली/2025 (नि.व. 2019-20) Abishek Chandok, Q5/2 First Floor, Dlf City Phase-Ii, Gurgaon, Haryana 122002 ...... अपीलार्थी/Appellant Pan: Apjpc-1686-E बिाम Vs. Income Tax Officer, Ward-51(1), Civic Centre Road, ..... प्रनिवादी/Respondent New Delhi 110002 अपीलार्थी द्वारा/Appellant By : Shri H.C Parasher & Ms. Hiteshi Parasher, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 15/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 15/12/2025 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri H.C Parasher & Ms. Hiteshi ParasherFor Respondent: Shri Manoj Kumar, Sr. DR

Section 143(2)Section 148Section 292B

apply the notice u/s.143(2) of the Act must have emanated from the Department. It is only the infirmities in the manner of service of notice that the section seeks to cure. The provisions of section 292BB of the Act does not intend to cure complete absence of notice itself

Ila Bhatnagar, Bhopal vs. Commissioner of Income Ta Appeals, Delhi

Appeal is allowed for statistical purpose

ITA 31/IND/2025[2017-18]Status: DisposedITAT Indore24 Dec 2025AY 2017-18

Bench: Shri Siddhartha Nautiyal

Section 144Section 253(5)

hearings to email id: sobhaniagarwal@diffmail.com as is noted by Ld. CIT(A) himself in Para 3.1 of impugned order. Therefore, due to non-service of notices at proper email id given by assessee in Form No. 35, the assessee could not attend hearings fixed by CIT(A), which

Gajendra Singh, Vidisha vs. Commissioner of Income-Tax (Appeals), NFAC, Delhi

Appeal is allowed for statistical purpose

ITA 285/IND/2025[2018-19]Status: DisposedITAT Indore24 Dec 2025AY 2018-19

Bench: Shri Siddhartha Nautiyal

Section 144Section 147Section 69A

impugned order and demonstrated that the CIT(A) has issued all notices of hearing through e- mail and there was no service of notice through physical mode. He submitted that the assessee runs a small kiosk of Union Bank of India in a remote place and not technology friendly, therefore

Kiran Kumar Soma, Hyderabad vs. ITO, Ward-1, Suryapet

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1318/HYD/2024[2014-15]Status: DisposedITAT Hyderabad24 Dec 2025AY 2014-15

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1318/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2014-15) Shri Kiran Kumar Soma Vs. Income Tax Officer Hyderabad Ward – 1 Pan: Baeps1869Q Suryapet (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Smt. K. Haritha, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 18/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Smt. K. Haritha, CIT (DR)

further invited our attention to Column No. 17 of Form No. 35, wherein the assessee had clearly provided the physical address for service of notices by the Ld. CIT(A). However, despite such specific denial of email communication, the notices issued by the Ld. CIT(A) were sent through email ... appeal before this Tribunal. The Ld. AR submitted that, as explained in the condonation petition, despite specific denial by the assessee for service of notices through email, the Ld. CIT(A) issued all notices only through email. As a result, the assessee could not effectively participate in the appellate proceedings

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5114/DEL/2025[2017-18]Status: DisposedITAT Delhi24 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

agri Thrift & Credit Society P&L account and other necessary documents having computation of income. Without affording proper opportunity and without service of notice, the assessment order dated 06.05.2023 was issued and addition of Rs. 6,04,79,580/- was made on account of cash deposited in bank account

The Hisar Leading Bank Co-Op Non-Agri Thrift & Credit Society, Hisar vs. Income-Tax Officer, Ward-1, Hisar

In the result, both appeals of the assessee are allowed

ITA 5113/DEL/2025[2016-17]Status: DisposedITAT Delhi24 Dec 2025AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Raj Kumar Chauhan

Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 68

Infinite Expeditions Pvt. Ltd., Modinagar, Ghaziabad, Uttar Pradesh vs. Income Tax Officer, Ward 2(1)(1), Ghaziabad

In the result, grounds of appeal raised by assessee are allowed

ITA 6968/DEL/2025[2018-19]Status: DisposedITAT Delhi23 Dec 2025AY 2018-19

Bench: Shri Pawan Singh(Physical Hearing) Infinite Expeditions Pvt. Ltd. Income Tax Officer, Ward 2(1)(1), B.K. Complex, S-3, Opp. Krishna Vs Ghaziabad. Kunj Colony, Tibra Road, Modinagar, Income Tax Building, Cgo Ghaziabad, Uttar Pradesh-201204 Complex-1, Purani Hapur Chungi, [Pan: Aaeci0872M] Ghaziabad, Uttar Pradesh-201002 Appellant / Assessee Respondent / Revenue Assessee By Shri Lakshay Gupta, Ca Revenue By Shri Virendra Kumar Singh, Sr. Dr Date Of Institution Of Appeal 31.10.2025 Date Of Hearing 01.12.2025 Date Of Pronouncement 23.12.2025 Order Under Section 254(1) Of Income Tax Act

Section 143(1)Section 147Section 148Section 148ASection 151ASection 254(1)Section 68

raised ground of appeal that reasonable opportunity of hearing was not given. The assessee also challenged the additions on merit. The assessee, on service of notice under section 250 filed their detailed written submissions. The submission of assessee are recorded at Page No.3 to 19 of order

Harish Chand Gupta, Delhi vs. Income Tax Officer, Ward 34(1), Delhi

In the result, the appeal of the assessee is allowed

ITA 671/DEL/2025[2017-18]Status: DisposedITAT Delhi23 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumarassessment Year : 2017-18 Harish Chand Gupta, Vs. Income Tax Officer, Bn-81, West Shalimar Bagh, Ward-34(1), Delhi – 110 088. Delhi. Pan: Aeupg0010Q (Appellant) (Respondent) Assessee By : Shri S.K. Gupta, Ca Revenue By : Shri Om Parkash, Sr. Dr Date Of Hearing : 29.10.2025 Date Of Pronouncement : 23.12.2025

For Appellant: Shri S.K. Gupta, CAFor Respondent: Shri Om Parkash, Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 144Section 250Section 68Section 69A

provisions of sec 292BB does not come to the rescue of the department as it is not a case of non- service of notice but a case of non-issue of notice. 8. The ld.DR submitted that the ld. AO had passed ex parte order. The ld.CIT

Krishna Kumar, Hisar vs. ITO Ward-02, Hisar

In the result assessee’s appeals ITA Nos

ITA 690/DEL/2023[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Ms. Madhumita Roy & Smt. Renu Jauhri

Section 147Section 148Section 271(1)(b)

acknowledgement either from the assessee or from the postal department. In that view of the matter in order to justify the service of notice under Section 148 of the Act dated 26.03.2019 the Id. DR is granted 15 days time to place on record the postal acknowledgment and/or proof ... same has not been returned back. Reopening of assessment under Section 147 of the Act can only be justified upon issuance and service of notice under Section 148 of the Act which is sine qua non and admittedly the same has not been established properly by the Department before

Krishan Kumar, Hisar vs. ITO Ward-2, Hisar

In the result assessee’s appeals ITA Nos

ITA 689/DEL/2023[2012-13]Status: DisposedITAT Delhi23 Dec 2025AY 2012-13

Bench: Ms. Madhumita Roy & Smt. Renu Jauhri

Section 147Section 148Section 271(1)(b)

ACIT, Circle-13(1), New Delhi vs. Jagat Projects Ltd., New Delhi

In the result, assessee’s cross objections C

ITA 1981/DEL/2022[2015-16]Status: DisposedITAT Delhi23 Dec 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Ms. Madhumita Royassessment Year: 2015-16

Section 143(2)Section 143(3)

been annexed to the communication dated 12.11.2025, however, the proof 6 of service is not forthcoming. Apparently it proves that there was no service of notice under Section 143(2) of the Act ever made on the assessee and therefore, entire proceeding is vitiated and thus, liable to be quashed ... facts and circumstances of the matter we also granted 15 days’ time to the Learned DR to place on record the proof of service of notice under Section 143(2) before us which the Learned DR has again failed to produce. Thus, having no other alternative in the absence

Saryu Devi, Ranchi vs. ITO, Ward-1(1), Ranchi

In the result, the appeal filed by the assessee is allowed

ITA 251/RAN/2025[20-21]Status: DisposedITAT Ranchi22 Dec 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.251/Ran/2025 Assessment Year: 2020-21 Saryu Devi…..………...…………….…….…............................……….……Appellant W/O Hira Nath Singh, Neori, Vikas, Sadar Ranchi, Jharkhand- 835217. [Pan: Geppd1201D] Vs. Ito, Ward-1(1), Ranchi…..….....…..…..….........……........……...…..…..Respondent Appearances By: Shri M. K. Choudhury, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : December 22, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Cit(A)”) Dated 10.06.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is An Individual Lady, Residing In A Village Area. She Had Not Filed Any Return Of Income For The Assessment Year 2021–22 As, According To Her, She Had No Taxable Income. The Assessee Was Not Registered On The Income-Tax E-Filing Portal During The Relevant Period. Her E-Filing Registration Was Done For The First Time On 09.03.2025. The Ao Received Information Through The Risk Management Strategy (Rms) That The Assessee Had Purchased Immovable Property For A Consideration Of ₹30,70,000. Based On This Information, Proceedings Under Section 147 Of The Act Were Initiated After Following

Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250Section 69A

served by email, by speed post, or by personal delivery. Therefore, the reassessment proceedings are void ab initio for want of valid service of notice. 5. On merits, it was submitted that the property in question was ancestral land. The land was transferred by her husband, Shri Hira I.T.A. No.251/Ran/2025 ... assessee was not registered on the income-tax portal during the relevant period. Her registration was done only on 09.03.2025. In such circumstances, service of notice through electronic mode was not possible. The assessee has categorically stated that no notice under section 148 of the Act was ever received, either

Lalba Krushnasinh Vaghela, Gandhinagar vs. The ITO, Ward 2, Gandhinagar

In the result, the appeal of the assessee stands allowed

ITA 1938/AHD/2025[2012-13]Status: DisposedITAT Ahmedabad22 Dec 2025AY 2012-13

Bench: Shri Sanjay Gargआयकर अपील सं /Ita No. 1938/Ahd/2025 िनधा"रण वष" /Assessment Year : 2012-13 Lalba Krushnasinh Vaghela Ito Ward 2, बनाम/ Plot No. 1068, Sector-2-D, Gandhinagar – 382 001 V/S. Gandhinagar, Gujarat – 382 007 "थायी लेखा सं./Pan: Akqpv 8914 N (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Pradeep Tulsian, Ar Revenue By : Shri Ravindra, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 16/12/2025 घोषणा की तारीख /Date Of Pronouncement: 22/12/2025 आदेश/O R D E R

For Appellant: Shri Pradeep Tulsian, ARFor Respondent: Shri Ravindra, Sr. DR

Section 69A

factually that was not correct as due to the specific software requirement of the income-tax department, that picks up the data of service of notice as mentioned in the record /software of the income-tax authorities and it does not allow to mention a different date of service ... notice. Therefore, the observation of the Ld. CIT(A) that the assessee, herself, has mentioned the service of notice as Lalba Krushnasinh Vaghela Vs. The ITO Ward 2 Asst. Year: 2012-13 3 05/12/2019 was not due to the fact that the assessee had actually become aware of the passing

R B Diamond House, Jalgaon vs. Pne-C-1, Range -25, Circle -1, Office of the Commissioner of Income Tax- Jalgaon

In the result, the appeal of the assessee is allowed for statistical

ITA 1948/PUN/2025[2016-17]Status: DisposedITAT Pune19 Dec 2025AY 2016-17

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1948/Pun/2025 निर्धारण वर्ष / Assessment Year : 2016-17 R B Diamond House, Opposite Manohar Sarees, Baliram Peth, Jalgaon-425001 Pan : Aaifr9130Q Vs. Pne-C-1, Range-25, Circle-1, Cit, Jalgaon अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sanjay T. Tupe Department By : Smt. Indira R. Adakil Date Of Hearing : 04-12-2025 Date Of Pronouncement : 19-12-2025 आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 10.06.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To Assessment Year (“Ay”) 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal :- "Ground No. 1: Ex-Parte Order Bad In Law 1. On The Facts & Circumstances Of The Case & In Law, The Ex Parte Order Passed By Cit(A)/ Nafc Is Bad In Law & Violates Principles Of Natural Justice. This Has Lead To A Denial Of Effective Opportunity For A Hearing. Ground No. 2: Violation Of Section 250(6) 2. On The Facts & Circumstances Of The Case & In Law, Cit(A)/ Nafc Failed To Comply With Section 250(6), Requiring Reasoned Findings On Each Ground Of Appeal. Ground No. 3: Non-Response Of Notices Due To Medical Issue 3. On The Facts & Circumstances Of The Case & In Law, Hearing Notices Were Not Responded To Due To The Illness Of Ms. Rupal Bagrecha Who Is Taking Care Of Accounting, All Income Tax & Other Statutory Compliances. Her E-Mail Id Rupalbagrecha21@Gmail.Com Is Registered On The Income Tax Portal. She Was Suffering From Severe Symptoms Of Epilepsy & Undergoing Medical Investigation From February 2025 Onwards, Preventing Timely Communication Of Notices To The Tax Consultant, Constituting Reasonable & Sufficient Cause For Non-Response.

For Appellant: Shri Sanjay T. TupeFor Respondent: Smt. Indira R. Adakil

Section 250(6)Section 69A

Income Tax Act, 1961 (the Act) were issued to the appellant through ITBA portal, as noted in para 2 above, which amounts to service of notice as provided u/s 282 of the Act. However, there has been no response from the appellant till date. There is no gainsaying that once

Shri Ramnikbhai Jasarajbhai Patel, at. Dhrangadhra, Dist. Surendranagar vs. The ITO Ward-3, Surendranagar

In the result, appeal of the assessee, is allowed for statistical purpose

ITA 244/RJT/2023[2013-14]Status: DisposedITAT Rajkot18 Dec 2025AY 2013-14

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Rupesh Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 144Section 148

notice u/s. 148 of the I.T. Act, the assessee was required to file his return of income within 30 days of service of notice. However, the assessee did not respond to the above said notice issued u/s. 148 of the LT. Act nor filed any return of income till date

Reshma Mohmad Suhed Sindhi, Anand vs. Income Tax Officer Ward 1 Anand, Anand

In the result, the appeal of the assessee is partly allowed for statistical purpose

ITA 687/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2017-18

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2017-18

For Appellant: Shri Piyush Panchal, A.RFor Respondent: Shri Rameshwar P. Meena, Sr. D.R

Section 133(6)Section 142(1)Section 143(1)Section 147Section 148Section 250Section 69A

prior approval of the Joint Commissioner of Income Tax, Baroda requiring the assessee to furnish return of income within 30 days from the service of notice. The assessee failed to file return of income within 30 days from the receipt of notice issued u/s. 148. Therefore, further notice

Cannon Industries Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle Mumbai

The appeal is dismissed limitation, is not maintainable

ITA 3329/MUM/2025[2008-2009]Status: DisposedITAT Mumbai18 Dec 2025AY 2008-2009

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2008-09

For Respondent: None

Income Tax Portal, so appeal is filled before you and also seeking condo nation of the delay. 2. We noted that despite due service of notice, n despite due service of notice, none appeared on one appeared on behalf of the assessee. No application seeking adjournment was behalf

Shri Kamleshkumar Vallabhbhai Chanchdia, Village Sardhar, Dist. Rajkot vs. The ITO-Ward-2(1)(2), Rajkot

In the result, appeal of the assessee, is allowed for statistical purpose

ITA 156/RJT/2021[2016-17]Status: DisposedITAT Rajkot16 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinha

For Appellant: Shri S. N. Divetia, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 68

note that the order of Ld.CITA) Page 3 of 4 ITA No. 156/RIT/2021 Kamleshkumar V. Chanchdla talk about the notice issued not about service of notice. We further note that assessee was not file the detail in supporting of addition of Rs.11,00000/- before AO. Weare of the view that

Safe and Sure Marine Services Private Limited, Mumbai vs. ITO (TDS), Ward 8(1)(1), Mumbai

In the result, the appeal of the assessee is partly allowed for partly allowed for 7

ITA 4566/MUM/2025[2013–14]Status: DisposedITAT Mumbai16 Dec 2025

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2013-14

For Respondent: None

Section 201Section 201(1)

necessary in the interest of be deemed necessary in the interest of justice. Ground 2. At the outset, it is noted that despite service of notice of At the outset, it is noted that despite service of notice of At the outset, it is noted that despite service of notice ... section 27 of the the lapse of more than one month. In terms of section 27 of the General Clauses Act, 1897, service of notice sent by registered post General Clauses Act, 1897, service of notice sent by registered post General Clauses Act, 1897, service of notice sent by registered