Section 127(1) of the Income Tax Act

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.

The jurisdiction of the Income-Tax Officer to reopen assessment proceedings under Section 147 is contingent upon the issuance of a valid notice under Section 148. If the Section 148 notice is invalid for any reason, all subsequent proceedings become void due to lack of jurisdiction.

Improper service of notice invalidates the entire reassessment proceedings. If no notice is served within the prescribed period, the Income-tax Officer is incompetent to commence reassessment proceedings.

An assessee's objection to an Income Tax Officer's jurisdiction, if it concerns the assumption of power in contravention of CBDT instructions rather than a dispute over territorial limits, means Section 124(3) does not aid the revenue.

Service of notice at a place other than the assessee's registered address violates assessment procedure and renders the notice invalid.

A fair hearing requires that a person be served with a proper, clear, and precise notice to enable them to make an effective defence. Ambiguity in notice denies the right to fair and judicious proceedings, and the adequacy of notice is determined on a case-by-case basis.

A show cause notice must be precise and unambiguous, clearly stating the case to be met, and adequate time must be given for the assessee to make a representation. Failure to do so vitiates the order.

A notice issued under section 148 is void ab initio if it is issued by an officer who lacks the jurisdiction to do so, and such a notice can be quashed.