“Section 282(1)(c)”

For reassessment under Section 147, the Assessing Officer must record reasons and communicate them to the assessee. An assessee's participation in proceedings pursuant to a Section 148 notice does not obviate the mandatory requirement of recording and communicating reasons or issuing a Section 143(2) notice.

Section 282 of the Income Tax Act, 1961 specifies the modes for serving notices, including by post or summons under the Code of Civil Procedure. A valid service of notice is essential for assessment or reassessment proceedings, and its absence renders such proceedings bad in law.

The genuineness of transactions, particularly the creditworthiness of creditors for share capital, is a key factor in the addition under section 68. The assessee must provide sufficient evidence to prove the genuineness of such transactions.

A notice is presumed to have been properly served if it is not returned as unserved, and objections regarding non-service are not acceptable in such cases.

Service of a notice or requisition under the Income-tax Act must be made in accordance with Section 282(1), which allows for service by post or as if it were a summons under the Code of Civil Procedure, 1908. Rules 12 to 15 of Order V of the CPC are relevant, emphasizing personal service where practicable.

The Revenue bears the burden of proving that a notice was duly served on the assessee or their authorized representative. If no valid notice is served within the prescribed period, the Income-Tax Officer lacks the authority to initiate reassessment proceedings.

For an assessee to be considered in default, a notice must be served in one of the modes provided by the Income Tax Act. Acquiring knowledge of a notice's issuance is not a substitute for proper service.

When no return is filed in response to a notice under section 148 of the Income Tax Act, a separate notice under section 143(2) is not required to make the assessment.