“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

Udai Lal Mahabir Prasad, India vs. Income Tax Officer, India

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

ITA 715/JPR/2025[2018-2019]Status: DisposedITAT Jaipur01 Aug 2025AY 2018-2019

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Tanuj Agarwal, AdvocateFor Respondent: Shri Gautam Singh Choudhary,JCIT-DR

Section 143(1)Section 154Section 40

MAHABIR PRASAD VS ITO, WARD-DAUSA check e-filing portal or registered email ID cannot be a ground to claim of non-service of notices. With these observations, Ld. CIT(A) rejected the contention on behalf of the appellant there that the intimation was physically not received and that ... notice of demand was served on the appellant on 17.11.2022. Although, no material has been placed on record regarding service of notice of demand on 17.11.2022, even if it is assumed to be correct, for the sake of arguments, the appellant has failed to explain as to why the intimation

Tdi Shiksha Sansthan, New Delhi vs. ITO, Ward Exmp 2(3), Delhi

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 6024/DEL/2024[2021-22]Status: DisposedITAT Delhi01 Aug 2025AY 2021-22

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

Section 10ASection 11

respectively. 2. When this matter has been called up for hearing, nobody has appeared from the side of the assessee despite service of notice. 3. After perusing the order of Ld. CIT(A), it is gathered that the CPC while processing the return of income for both these years have

Tdi Shiksha Sansthan, New Delhi vs. ITO, Ward Exmp-2(3), Delhi

In the result, both appeals of the assessee are allowed for statistical purposes

ITA 6023/DEL/2024[2020-21]Status: DisposedITAT Delhi01 Aug 2025AY 2020-21

Bench: Shri Prakash Chand Yadav & Shri Manish Agarwal

Section 10ASection 11

Komma Tulasi Ram Kumar, Vijayawada vs. Income Tax Officer, Ward (International Taxation), Vijayawada

In the result appeal of assessee is partly allowed

ITA 203/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam31 Jul 2025AY 2017-18

Bench: Shri Vijay Pal Rao, V.P. & Shri Manjunatha G. A.M.

For Appellant: Sri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR

Section 115BSection 127Section 143(2)Section 143(3)Section 69A

Before the CIT(A), the assessee challenged the assessment order passed by the Assessing Officer on various grounds including non-service of notice issued u/sec.143(2) of the Act and also jurisdiction of the Assessing Officer who passed the assessment order in light a provisions of section ... jurisdiction of the Assessing Officer. 4. The learned CIT(A) had also rejected other legal ground taken by the assessee including non-service of notice under section 143(2) of the Income Tax Act, 1961 on the ground that, on perusal of the remand report of the 5 ITA.No.203/Vizag/2024

Dy.CIT, Circle 1(1) & Tps, Thrissur vs. Arun Majeed, Thrissur

In the result, the appeal filed by the Revenue stands allowed

ITA 388/COCH/2025[2013-14]Status: DisposedITAT Cochin31 Jul 2025AY 2013-14

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2013-14 Dy. Cit, Circle 1(1) & Tps, Thrissur .......... Appellant [Pan: Adopa9351R] Vs. Arun Majeed .......... Respondent Palak Velyannur Temple Road Veliyannur, Thrissur 680021 Appellant By: Smt. Leena Lal, Sr. D.R. Respondent By: ------- None ------- Date Of Hearing: 05.06.2025 Date Of Pronouncement: 31.07.2025

For Appellant: Smt. Leena Lal, Sr. D.RFor Respondent: ------- None -------

Section 132Section 143(3)Section 153ASection 271(1)(c)Section 271(1)(i)Section 274

before this Tribunal in the present appeal. 6. When the appeal was called on nobody appeared on behalf of the assessee despite due service of notice of hearing. Therefore, we proceeded to dispose of the appeal after hearing the learned Sr. DR. 7. The learned Sr. DR submits that

Monzey Varghese, Pallipuram vs. Income Tax Commisioner, Mattanchery

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 367/COCH/2025[2017-18]Status: DisposedITAT Cochin31 Jul 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri K.K. Jose, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 148

Exemptions) (2024) 463 ITR 560 (P&H), wherein the Hon’ble High Court after making reference to provisions of 282(1) held that service of notice through ITBA portal is not valid service and remanded the matter to AO for denovo disposal of case. The relevant paragraphs of the judgment ... rule 127(1) of the Income-tax Rules, 1962 provides for a method and manner of service of notice and orders which read as follows : . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8. In view of the above, it is essential that before any action is taken, communication of the notice must be done in terms

Monzey Varghese, Pallipuram vs. Income Tax Officer, Mattanchery

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 366/COCH/2025[2016-17]Status: DisposedITAT Cochin31 Jul 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri K.K. Jose, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 148

Monzey Varghese, Pallipuram vs. Income Tax Officer, Mattanchery

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 365/COCH/2025[2015-16]Status: DisposedITAT Cochin31 Jul 2025AY 2015-16

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri K.K. Jose, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 148

Sunil Melathilveedu Nazarudeen, Oyoor vs. ITO Ward 3, Kollam

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

ITA 363/COCH/2025[2017-18]Status: DisposedITAT Cochin31 Jul 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2017-18 Sunil Melathilveedu Nazarudeen .......... Appellant Melathil Veedu, Payyacode, Oyoor, Kollam [Pan: Aefpn3764B] Vs. The Income Tax Officer, Wd-3, Kollam 691510.......... Respondent Appellant By: Shri R. Krishnan, Ca Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 13.06.2025 Date Of Pronouncement: 31.07.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 31.01.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual. No Regular Return Of Income For Ay 2017-18 Was Filed By The Appellant Under The Provisions Of Section 139(1) Of The Income Tax Act, 1961 (The Act). The Income Tax Officer, Ward-3, Kollam (Hereinafter Called "The Ao") Had Come To Know That The Appellant

For Appellant: Shri R. Krishnan, CAFor Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 142(1)Section 144Section 282(1)

issued by the National Faceless Appeal Centre trough ITBA portal. In our considered opinion, it is not a valid method and manner of service of notice as specified under the provisions of section 282(1) of the Income-tax Act, 1961 Act and Rule 127(1) of the Income ... Exemptions) (2024) 463 ITR 560 (P&H), wherein the Hon’ble High Court after making reference to provisions of 282(1) held that service of notice through ITBA portal is not valid service and remanded the matter to AO for denovo disposal of case. The relevant paragraphs of the judgment

Mooladeth Fathima Noor, Calicut vs. ITO, Ward 1(3), Calicut

In the result, the appeal filed by the assessee stands dismissed

ITA 312/COCH/2025[2014-15]Status: DisposedITAT Cochin31 Jul 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2014-15 Mooladeth Fathima Noor .......... Appellant Noor Mahal, Devagiri, Medical College Calicut 673008 [Pan: Abzpf8525H] Vs. The Income Tax Officer,Wd-1(3), Calicut .......... Respondent Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 05.06.2025 Date Of Pronouncement: 31.07.2025

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 54Section 54F

before this Tribunal in the present appeal. 5. When the appeal was called on nobody appeared on behalf of the assessee despite due service of notice of hearing. Therefore, we proceeded to dispose of the appeal after hearing the learned Sr. DR, who supporting the order of the learned

Pathanamthitta Sndp Union Development and Welfare Society, Konni vs. ITO, Exemption Ward, Alappuzha

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

ITA 168/COCH/2025[2018-19]Status: DisposedITAT Cochin31 Jul 2025AY 2018-19

Section 10Section 12ASection 143(3)Section 57

before this Tribunal in the present appeal. 5. When the appeal was called on, nobody appeared on behalf of the assessee despite due service of notice of hearing. Therefore, we proceeded to dispose of the appeal after hearing the learned Sr. DR. 6. Through the grounds of appeal filed

Remya Vikraman Nair Rema Devi, Trivandrum vs. ITO, Ward 1(1), Trivandrum

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

ITA 701/COCH/2024[2016-17]Status: DisposedITAT Cochin31 Jul 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2016-17 Remya Vikraman Nair Rema Devi .......... Appellant 79 2290, Mudumbil Puthenveedu Karikkakom, Thiruvananthapuram 695007 [Pan: Cdmpr5619H] Vs. Ito, Ward-1(1), Thiruvananthapuram .......... Respondent Appellant By: ------- None ------- Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 10.06.2025 Date Of Pronouncement: 31.07.2025

For Appellant: ------- None -------For Respondent: Smt. Leena Lal, Sr. D.R

Section 139(1)Section 147Section 148Section 55(2)

before this Tribunal in the present appeal. 5. When the appeal was called on nobody appeared on behalf of the assessee despite due service of notice of hearing. The matter ws adjourned four times. Therefore, we proceeded to dispose of the appeal on merits after hearing the learned

ACIT, Trichur vs. M/S. Atlas Jewellery India Ltd, Delhi

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 8/COCH/2020[2014-15]Status: DisposedITAT Cochin31 Jul 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Shivakumar S., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 132Section 143(3)Section 153ASection 37Section 40

before this Tribunal in the present appeal. 13. When the appeal was called on nobody appeared on behalf of the assessee despite due service of notice of hearing. Therefore, we proceeded to dispose of the appeal after hearing the ld. CIT-DR. 14. The ld. CIT-DR submits that

ACIT, Trichur vs. M/S. Atlas Jewellery India Ltd, Delhi

In the result, the appeals filed by the assessee stand partly allowed for statistical purposes

ITA 7/COCH/2020[2014-15]Status: DisposedITAT Cochin31 Jul 2025AY 2014-15

Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm

For Appellant: Shri Shivakumar S., CAFor Respondent: Shri Sanjit Kumar Das, CIT-DR

Section 132Section 143(3)Section 153ASection 37Section 40

Badam Singh, Bhopal vs. ITO 4(1), Bhopal

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

ITA 127/IND/2025[2013-2014]Status: DisposedITAT Indore31 Jul 2025AY 2013-2014

Bench: B.M. Biyani & Shri Paresh M Joshibadam Singh, Income Tax Officer- बनाम/ 392 Gram Palasi, 4(1), Vs. New Jail Road, Bhopal Karond, Bhopal (Pan: Drhps5664B) (Appellant) (Revenue) Assessee By Shri S.S. Solanki, Ars Revenue By Shri Ashish Porwal, Dr Date Of Hearing 31.07.2025 Date Of Pronouncement 31.07.2025 आदेश / O R D E R

Section 143Section 246ASection 250Section 253Section 282

notices u/s. 250 of the Act were issued to the appellant through ITBA portal, as noted in paragraph 6 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 gain saying that ... seems like an afterthought, as there is no evidence with respect to the same. The assessment order clearly brings out the issue and service of notice as also the providing of reasons for issue of notice u/s 148 to the AR of the assessee. In view of the foregoing, these

Pravinbhai Jethabhai Patel, Kheda vs. The ITO, Ward-5, Nadiad

In the result, the appeal of the assessee is allowed

ITA 137/AHD/2025[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyalpravinbhai Jethabhai Patel, Income Tax Officer, Vs. Teen Khadki, Nr. Bar Ni Khadki, Ward-5, Village-Nar, Tal. Petlad, Nandiad. Kheda-388150. [Pan :Biqpp9029 K] (Appellant) .. (Respondent) Appellant By : Shri Jamin Shah, Ar Respondent By: Shri Bp Makwana, Sr. Dr Date Of Hearing 16.07.2025 Date Of Pronouncement 31.07.2025 O R D E R Per Dr. B.R.R. Kumar, Vice-:- This Appeal Has Been Filed By The Assessee Against The Order Dated 21.11.2024, Passed By The Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (Hereinafter Referred To As "Cit(A)" For Short), U/S 250 Of The Income-Tax Act, 1961, (Hereinafter Referred To As "The Act" For Short) For The Assessment Year 2011-12. 2. The Assessee Has Raised The Following Grounds Of Appeal :

For Appellant: Shri Jamin Shah, ARFor Respondent: Shri BP Makwana, Sr. DR

Section 142(2)Section 143(2)Section 147Section 148Section 210Section 234ASection 250Section 271(1)(c)Section 56(2)(vii)

binding precedents of the Hon’ble Apex Court and the jurisdictional High Court, we hold that the non-issuance and non-service of notice u/s 143(2) renders the reassessment order null and void. Liberty is given to the Revenue to approach the Tribunal in case they could prove issuance

Dar E Aqram Eductaion Charitable Trust, Pune vs. ITO Exemption Ward 1(2), Pune

In the result, both the appeals in ITA Nos

ITA 739/PUN/2025[2023-24]Status: DisposedITAT Pune31 Jul 2025AY 2023-24

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita Nos.738 & 739/Pun/2025 Dar E Arqam Education Charitable Trust, Galli No. 9, Sr. No. 54, Shivneri Nagar, Kondhwa Khurd, Pune-411048 Vs. Ito, Exemption, Ward – 1(2), Pune Pan: Aactd0454F अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Piyush Bafna Department By : Shri Amol Khairnar Date Of Hearing : 30-07-2025 Date Of Pronouncement : 31-07-2025 आदेश / Order Per Astha Chandra, Jm : The Above Two Appeals Filed By The Assessee Are Directed Against The Separate Orders Both Dated 18.03.2024 Of The Ld. Commissioner Of Income Tax (Exemption), Pune (“Cit(E)") Rejecting The Application(S) For Grant Of Registration U/S 12A & Approval U/S 80G Of The Income Tax Act, 1961 (The "Act") Filed On 29.09.2023 & 30.09.2023 Respectively. For The Sake Of Convenience, Both These Appeals Were Heard Together & Are Being Disposed Of By This Common Order. 2. Both The Appeals Have Been Filed With A Delay Of 293 Days Before The Tribunal For Which The Assessee Has Filed An Affidavit Explaining The Reasons For Such Delay. On Perusal Of The Same, We Are Satisfied That The Delay In Filing Of Appeal Is Not Intentional Or Deliberate But Has Occurred For The Reasons Mentioned In The Affidavit. After Hearing Both The Sides, We Are Of The View That The Delay Is Attributable To The Sufficient Cause. We, Therefore, In Light Of The Decisions Of The Hon'Ble Supreme Court In The Case Of Collector, Land Acquisition Vs. Mst. Katiji & Ors. (1987) 167 Itr 471 (Sc) & In The Case Of Inder Singh Vs. The State Of Madhya Pradesh Reported In 2025 Livelaw (Sc) 339, Condone The Said Delay & Proceed To Decide The Appeal. 3. In Ita No.738/Pun/2025, The Assessee Has Challenged The Order Of The Ld. Cit(E) In Rejecting The Application For Registration U/S 12A Of The Act While

For Appellant: Shri Piyush BafnaFor Respondent: Shri Amol Khairnar

Section 12ASection 12A(1)(ac)Section 36ASection 80G

Exemption), Pune has erred in rejecting the application without affording adequate opportunity of being heard and without ensuring proper service of notices in accordance with the law. Unjustified Cancellation of Provisional Approval 6. On the facts and in the circumstances of the case, the Hon'ble CIT(Exemption), Pune

Dar E Arqam Education Charitable Trust, Pune vs. ITO Exemption Ward 1(2), Pune

In the result, both the appeals in ITA Nos

ITA 738/PUN/2025[2023-24]Status: DisposedITAT Pune31 Jul 2025AY 2023-24

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Piyush BafnaFor Respondent: Shri Amol Khairnar

Section 12ASection 12A(1)(ac)Section 36ASection 80G

Late Abdul Rahiman Ibrahim Patait L/H Mujeeb Patait, Ratnagiri vs. Income Tax Officer, Ratnagiri

In the result, appeal of the assessee is allowed

ITA 1570/PUN/2025[2017-18]Status: DisposedITAT Pune31 Jul 2025AY 2017-18

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1570/Pun/2025 िनधा"रण वष" / Assessment Year: 2017-18 Late Abdul Rahiman Ibrahim V The Income Tax Officer, Patait Through Legal Heir S Ward-1, Ratnagiri. Mujeeb Abdul Patait, 318, Kanhe Mohala, Ap Kanhe, Tal Chiplun, Ratnagiri-415604. Pan: Adspp6791D Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Arvind Renge – Addl.Cit(Dr) Date Of Hearing 28/07/2025 Date Of Pronouncement 31/07/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By Mr.Mujeeb Patait As Legal Heir Of Late Abdul Rahiman Ibrahim Patait, Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2017-18 Dated 25.03.2025, Emanating From Order U/S.147 R.W.S 144 Of The Income

Section 142(1)Section 147Section 159Section 250

Madhav Vishwanath Dawalbhakta ... Vs. M/s.Bendale Brothers Writ Petition No.4217 of 2018 vide order dated 7th August, 2018, explained the concept of service of Notice as under : Quote “23. The service is neither an empty formality nor procedural ritual but the soul of the service is to have the knowledge

Channarayapatna Nanjappa Chandregowda, Hassan vs. ITO, Ward 1 & Tps, Hassan

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

ITA 2371/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Jul 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year : 2016-17

For Appellant: Mr. Zain Ahmed Khan, CAFor Respondent: Shri Shivanand Kalakeri, CIT-DR

Section 142(1)Section 143(2)Section 147Section 148Section 68Section 69

concentrate any of the activities. 5. The Ld.DR relied on the orders of the lower authorities and also filed a submission about the service of notice u/s. 143(2) of the Act. 6. We have heard the arguments of both sides and perused the materials available on record. Page