“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

Ashokkumar Bhulabhai Rathod, Mahuva vs. NFAC, Delhi Current Jurisdiction - ITO Ward 1 Bardoli, Bardoli

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

ITA 1255/SRT/2024[2015-16]Status: DisposedITAT Surat19 Jun 2025AY 2015-16

Bench: Shri Tr Senthil Kumar & Shri Bijayananda Prusethआयकर अपील सं./Ita Nos.1253 To 1255/Srt/2024 Assessment Years: 2013-14 To 2015-16) (Hybrid Hearing) Ashokkumar Bhulabhai Rathod Nfac, Delhi Current Opp. Reliance Tower, Vs Jurisdiction-Income Tax Officer, Karcheliya, Mahuva-394 240 . Ward No.1, Bardoli, Income-Tax Office, 2Nd Floor, Opp. Jalaram Temple, Station Road, Bardoli- 394 601 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Abxpr 3858 F (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Rasesh Shah, Ca राज" की ओर से /Respondent By Ms. Neerja Sharma, Sr-Dr सुनवाई की तारीख/Date Of Hearing 07/05/2025 उद्घोषणा की तारीख/Date Of Pronouncement 19/06/2025 आदेश / O R D E R Per Bench: These Three Appeals By The Assessee Emanate From The Separate Orders Passed Under Section 250 Of The Income-Tax Act, 1961 (In Short, ‘The Act’) All Dated 30.09.2024 By The National Faceless Appeal Centre (Nfac),Delhi/Commissioner Of Income-Tax (Appeals) [In Short, ‘Nfac/Ld. Cit(A)’] For The Assessment Years (Ay) 2013-14, 2014-15 & 2015-16, Which In Turn Arose Out Of Separate Assessment Orders Passed By Assessing Officer (In Short, ‘Ao’) U/S 147 R.W.S. 144 R.W.S. 144B Of The Act Dated 24.05.2023, 18.05.2023 & 19.05.2023. Since Facts Are Same Except Variance Of Amounts, With Consent Of The Parties, The Appeals Were Heard Together & A Common

Section 147Section 148Section 148ASection 250Section 69A

Form-35. The Ld. AR has submitted screen shot of the said notices to support his claim that there was no proper service of notice. Hence, the order of CIT(A) was passed without ITA No.1253-1255/SRT/2024/AYs.13-14-15-16 Ashokkumar B Rathod giving reasonable and sufficient opportunity of being heard to assessee. This

Ashokkumar Bhulabhai Rathod, Mahuva vs. NFAC, Delhi Current Jurisdiction - ITO Ward - 1, Bardoli

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

ITA 1254/SRT/2024[2014-15]Status: DisposedITAT Surat19 Jun 2025AY 2014-15

Section 147Section 148Section 148ASection 250Section 69A

Ashokkumar Bhulabhai Rathod, Mahuva vs. NFAC, Delhi Current Jurisdiction - ITO Ward 1, Bardoli

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

ITA 1253/SRT/2024[2013-14]Status: DisposedITAT Surat19 Jun 2025AY 2013-14

Section 147Section 148Section 148ASection 250Section 69A

Vikas Mineral Foods Pvt. Ltd., Chandigarh vs. Income Tax Officer, Ward 3(4), Chandigarh

In the result, the appeal of the assessee is allowed

ITA 1001/CHANDI/2024[2011-12]Status: DisposedITAT Chandigarh19 Jun 2025AY 2011-12

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1001/Chd/2024 "नधा"रण वष" / Assessment Year: 2011-12 Vikas Mineral Foods Pvt.Ltd., The Ito, House No.20, Nac, Vs Ward 3(4), Shivalik Enclave, Chandigarh. Mani Majra. "थायी लेखा सं./Pan No: Aabcv2453J अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Harry Rikhy, Advocate Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr Date Of Hearing : 26.05.2025 Date Of Pronouncement : 19.06.2025 Physical Hearing O R D E R

For Appellant: Shri Harry Rikhy, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR

Section 249Section 253Section 3Section 5

deem it appropriate to adjourn the hearing to 20.05.2025. The AO is directed to send assessment record which should contain the evidence of service of notice upon the assessee, as discussed above. This appeal be treated as part heard. Copy of this ordersheet be supplied to both the parties.” Thereafter ... original assessment record has been produced before us but it does not contain any postal receipts or receipts from Courier Agency exhibiting the service of notice upon the assessee. The ld. Sr.DR has produced Dispatch Register of the Range and according to her, the notice was stated to be dispatched

Neelam Rai, Raipur vs. Income Tax Officer, Ward-1(1), Bilaspur

Appeal of the assessee is allowed for statistical purposes, in terms of over aforesaid observations

ITA 97/RPR/2025[2016-17]Status: DisposedITAT Raipur18 Jun 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 97/Rpr/2025 (िनधा"रण वष" Assessment Year: 2016-17)

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151Section 15lSection 250Section 69Section 69A

about the notices issued, as the same were communicated on a different email-ID than the ID opted by the assessee, therefore, the service of notice to the assessee cannot be considered as a valid service, in accordance with the mandate of law. It was the request that the matter

Rama Rao Gudimella, Warangal vs. Income Tax Officer, Ward-1, Warangal

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

ITA 505/HYD/2025[2021-22]Status: DisposedITAT Hyderabad18 Jun 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: Dr. Sachin Kumar, SR-DR

Section 143(3)

Form No. 35 filed before the Ld. CIT(A) and submitted that the assessee had specifically mentioned his email ID as ramarao_hitek@yahoo.com for service of notices. The Ld. AR further pointed out that the Ld. CIT(A) had instead sent the notices to a different email ID, which although belongs ... either side. On perusal of Form No. 35, we note that the assessee had clearly mentioned ramarao_hitek@yahoo.com as the communication email ID for service of notices. However, from the copy of the notices issued by the Ld. CIT(A), placed on record by the Ld. AR, it is evident that

Assistant Commissioner of Income Tax, Delhi vs. Satvinder Kaur, Delhi

In the result, appeal of the Revenue is dismissed

ITA 3185/DEL/2024[2016-17]Status: DisposedITAT Delhi18 Jun 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalassistant Commissioner Of Vs. Satvinder Kaur Income Tax S-493, Greater Kailsah E-2, Block, Pratyaksh Kar Part-Ii, Bhawan, Dr. Shyama New Delhi Prasad Mukherjee Civic Pan: Aaxpk8350J Centre, Jawaharlal Nehru Marg, New Delhi Appellant Respondent Assessee By Advocate V. K. Sabharwal, Advocate Rajiv Kumar & Ca S. S. Aggarwal Revenue By Sh. Sahil Kumar Bansal, Sr. Dr Date Of Hearing 22/05/2025 Date Of Pronouncement 18/06/2025 Order Per Yogesh Kumar, U.S. Jm: The Present Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax Appeal/National Faceless Appeal

Section 144BSection 147Section 148Section 153ASection 153C

proceedings u/s 153A. 2 Whether on the facts and circumstances of the case, the CIT(A) has erred in challenging the validity of service of notice as the notice u/s 148 of the Act was issued on 31.03.2021 through ITBA within prescribed time limit. 2 ACIT Vs. Satvinder Kaur ... vide order dated 13/02/2024, allowed the Appeal of the Assessee on the ground that there was no valid service of notice u/s 148 of the Act within the prescribed time limit. As against the order of the Ld. CIT(A) dated 13/02/2204, the Revenue preferred the present Appeal. 3 ACIT

Geopetrol International Inc., Chennai vs. ACIT, Circle International Taxation1(3)1, New Delhi

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

ITA 2416/DEL/2022[2018-19]Status: DisposedITAT Delhi18 Jun 2025AY 2018-19

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI BRAJESH KUMAR SINGH (Accountant Member)

For Appellant: S/Shri Sanchit Jain, Advocate &For Respondent: S/Shri Vijay B Vasanta, CIT- DR &

Section 135Section 143(2)Section 143(3)Section 144CSection 144C(15)Section 144C(15)(b)Section 234ASection 282Section 40Section 92C

email id. Even, the draft assessment order was sent to the assessee on email id which was not furnished to the department for service of notice. He submitted that where the notices were not served on the assessee on the email id as specified under Rule 127 of the Income ... Income Tax Rules, 1962. The contention of the assessee is that the assessee had given an email id ramya@geopetrol.net for service of notice. Whereas, the notice/draft assessment order was sent to the mail id ajay.asri@geopetrol.net which is not operational. The contention of the assessee 9 is that since the draft

Gajanan Jagannath Kalbhor, Pune vs. ITO Ward 14(3), Pune

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

ITA 1075/PUN/2025[2012-13]Status: DisposedITAT Pune17 Jun 2025AY 2012-13

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1075/Pun/2025 Assessment Year : 2012-13

For Appellant: NoneFor Respondent: Shri S. Sadananda Singh

Section 133(6)Section 144Section 148Section 250Section 250(6)Section 69A

passed u/s.144 r.w.s.147 of the Act. 2. When the case was called for, none appeared on behalf of the assessee despite due service of notice of hearing. With the assistance of ld. Departmental Representative and on the basis of material available on record, I proceed to adjudicate the appeal

Daraius Homi Bilimoria, Mumbai vs. Commissioner of Income Tax (Appeal)-55, Mumbai

In the result, the various grounds of appeal raised by the

ITA 2593/MUM/2025[2019-20]Status: HeardITAT Mumbai17 Jun 2025AY 2019-20

Bench: Shri Pawan Singh & Shri Prabhash Shankar(Physical Hearing) Daraius Homi Bilimoria Commissioner Of Income Tax C/O Hfk Madan, 308, Apeejay House, Vs (Appeals) -55, Mumbai. 130, Shahid Bhagatsingh Marg, Mumbai – 400001. [Pan No. Aacpb4087E] Appellant / Assessee Respondent / Revenue

Section 112Section 254(1)Section 48Section 55(2)(b)Section 55A

Daraius Homi Bilimoria of documents of purchase and sale and the details of income from other sources. The assessing officer recorded that despite service of notices dated 29.05.2021, 02.07.2021 and 15.07.2021, the assessee made no compliance. The assessing officer passed draft assessment order under section 144C

Bhupesh Pralhadrao Patil, Dhule vs. National Faceless Assessment Centre, Delhi

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

ITA 437/PUN/2025[2017-18]Status: DisposedITAT Pune16 Jun 2025AY 2017-18

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.437/Pun/2025 Assessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Ramnath P. Murkunde

Section 142(1)Section 144Section 147Section 148Section 194HSection 194ISection 194JSection 250

passed u/s.147 r.w.s.144 r.w.s.144B of the Act. 2. When the case was called for, none appeared on behalf of the assessee despite due service of notice of hearing. With the assistance of ld. Departmental Representative we proceed to adjudicate the appeal exparte qua the assessee. 2 Bhupesh Pralhadrao Patil

Champalal Mangilal Jain, Nandurbar vs. Income Tax Officer, Ward-N Dhule, Dhule

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

ITA 422/PUN/2025[2012-2013]Status: DisposedITAT Pune16 Jun 2025AY 2012-2013

Bench: Dr.Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.422/Pun/2025 Assessment Year : 2012-13

For Appellant: NoneFor Respondent: Shri Ramnath P. Murkunde

Section 139(1)Section 142(1)Section 144Section 148Section 250Section 250(6)Section 69A

passed u/s.144 r.w.s.147 of the Act. 2. When the case was called for, none appeared on behalf of the assessee despite due service of notice of hearing. However, assessee vide letter dated 05.06.2025 sought adjournment. The said letter seeking adjournment was received by the Registry only after the conclusion

Omprakash Asaram Mantri, Jalna vs. ACIT Central Circle 1, Aurangabad

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

ITA 1011/PUN/2025[2014-15]Status: DisposedITAT Pune16 Jun 2025AY 2014-15

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.1011/Pun/2025 Assessment Year : 2014-15

For Appellant: NoneFor Respondent: Shri Dayanand Jawalikar

Section 132Section 143(3)Section 250Section 250(6)

passed u/s.143(3) of the Act. 2. When the case was called for, none appeared on behalf of the assessee despite due service of notice of hearing. With the assistance of ld. Departmental Representative and on perusal of record, we proceed to adjudicate the case. We on perusal

Jayesh Ramesh Chaudhari, Dharangaon vs. Income Tax Officer, Ward 2(3), Jalgaon

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

ITA 2615/PUN/2024[2012-2013]Status: DisposedITAT Pune16 Jun 2025AY 2012-2013

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2615/Pun/2024 Assessment Year : 2012-13

For Appellant: NoneFor Respondent: Date of hearing

Section 144Section 250

passed u/s.144 r..w.s.147 of the Act. 2. When the case was called for, none appeared on behalf of the assessee despite due service of notice of hearing. With the assistance of ld. Departmental Representative and on perusal of record, we proceed to adjudicate the grounds of appeal raised before

Dinesh Oils Ltd, Kanpur vs. Assistant Commissioner of Income Tax, Centreal Circle-1, Kanpur

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

ITA 117/LKW/2023[2017-18]Status: DisposedITAT Lucknow11 Jun 2025AY 2017-18

Bench: Shri Kul Bharat & Shri Nikhil Choudharyआयकर अपील सं/ Ita No.117/Lkw/2023 "नधा"रण वष"/ Assessment Year: 2017-18 Dinesh Oils Ltd V. Acit, Central Circle-1 3/48, Vishnupuri, Kanpur- Laxmi Niwas, 10/453, 208002. Tilak Nagar, Kanpur. Pan:Aaacd4990K अपीलाथ"/(Appellant) ""यथ"/(Respondent) अपीलाथ" "क और से/Appellant By: None ""यथ" "क और से /Respondent By: Shri R. K. Agarwal, Cit(Dr) सुनवाई "क तार"ख / Date Of Hearing: 05 06 2025 घोषणा "क तार"ख/ Date Of 11 06 2025 Pronouncement: आदेश / O R D E R

For Appellant: NoneFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 115BSection 143(2)Section 144Section 68

reasoning was put across as to why the notices could not reach the assessee. Hence the conduct of assessment proceedings without the mandatory service of Notices is wholly illegal and patently without jurisdiction. The Department Page 2 of 5 is prayed to adduce evidence/strict proof of service of Notices

Income Tax Officer Ward 6(3), Pune vs. Janata Automobiles, Pune

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

ITA 1779/PUN/2024[2017-18]Status: DisposedITAT Pune11 Jun 2025AY 2017-18

Bench: Shri R. K. Panda & Ms Astha Chandraassessment Year : 2017-18

For Appellant: NoneFor Respondent: Shri Ramnath P Murkunde

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

side of the assessee for which the notice was sent through the Ld. DR to be served on the assessee. Despite such service of notice on the assessee, there was no compliance from the side of the assessee. When the name of the assessee was called today, neither anybody appeared

Alumni Association of Indubhai Parekh School of Architecture - Rajkot, Rajkot vs. Commissioner of Income-Tax (Exemption), Ahmedabad

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

ITA 940/RJT/2024[NA]Status: DisposedITAT Rajkot10 Jun 2025

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकर अपील सं./Ita No. 940/Rjt/2024 (िनधा"रण वष" / Assessment Year: (N.A.) (Hybrid Hearing) Alumni Associa"On Of Indubhai Parekh School Vs. The Cit(Exemp"On), Ahmedabad Of Architecture, Rajkot- 360005, Gujarat India "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahta9691E (Appellant) (Respondent)

For Appellant: Shri Kamal Bhambhani, Ld. ARFor Respondent: Shri Sanjay Pungalia, Sr.D.R

Section 12ASection 12A(1)(ac)

without considering the fact that no notices were served to the appellant trust neither in its email address nor on its postal address. Service of notice granting a reasonable opportunity of being heard is an essential element of all administrative decision-making. Looking to the activities carried

Irm Private Limited, Ahmedabad vs. The DCIT, Circle-2(1)(1), Ahmedabad

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

ITA 1590/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad10 Jun 2025AY 2011-12

Bench: Shri T.R. Senthil Kumar & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 1590/Ahd/2024 िनधा"रण वष" /Assessment Year : 2011-12 Irm Private Limited, The Deputy Commissioner Irm House, बनाम/ Of Income Tax, V/S. Off. C.G Raod, Circle 2(1)(1), Navrangpura, Ahmedabad. Ahmedabad-380009. "थायी लेखा सं./Pan: Aaaci3678M अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Bandish Soparkar, Ar Revenue By : Shri Abhijit, Sr-Dr

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Abhijit, SR-DR

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 144Section 147Section 148Section 14ASection 194HSection 194J

denied it the opportunity of personal hearing despite repeated requests. It was also submitted that the assessment was completed ex-parte due to service of notices at IRM House, whereas the administrative office was functioning from Bhat, as recorded on PB Pg 10–11. We note that the assessment

Maa Harsidhhi Infra Developers Pvt. Ltd., Bilaspur vs. Deputy Commissioner of Income Tax-1(1), Bilaspur

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

ITA 167/RPR/2025[2022-23]Status: DisposedITAT Raipur09 Jun 2025AY 2022-23

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.167/Rpr/2025 "नधा"रण वष" / Assessment Year : 2022-23 Maa Harsiddhi Infra Developers Private Limited H No. Peepal 1/83, Housing Board Colony, Boriyakala, Raipur (C.G.) Pan: Aagcm7052H

For Appellant: Shri G.S. Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 250

u/s.250 of the Act on various dated is summarized as under: Sr. Notice issuing Date fixed for Way of Result No. Date hearing service of Notice 1. 19/12/2024 26/12/2024 E-mail No compliance 2. 30/12/2024 06/01/2025 E-mail No compliance 3 Maa Harsiddhi Infra Developers Private Limited Vs. DCIT, Central

Rupa Vimal Padaliya, Rajkot vs. DCIT, Circle-1(1), Rajkot

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

ITA 821/RJT/2024[2018-19]Status: DisposedITAT Rajkot09 Jun 2025AY 2018-19

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaarrester /Ita No. 821 /Rit/ 2024 (Fara / Assessment Year: (2018-19) (Hybrid Hearing)

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 147Section 148Section 69

hearings of the case. We further note that the order of the CIT(A) is silent on service of notices upon the assessee. That the Ld. CIT(A) has dismissed the appeal of the assessee in imine without going into merits of the case. We note that the assessee