Court held that notice without recording satisfaction is held to be not valid however, subsequent notice after valid satisfaction is held to be valid. Court also held that High court can find out whether proper satisfaction is recorded or not, however cannot consider sufficiency of reasons. The provisions of section 282 deal with service of notice in general terms and section 282A with the authentication of notices for service by electronic means. In this case, it was not in dispute that the notice dated September 30, 2019 was a valid notice qua the provisions of sections 282 and 282A read with rules 127 and 127A. The issuance of notice dated June 14, 2019 did not vitiate the proceedings in any way. (AY. 2017-18)
6th Sense Infrastructure Pvt. Ltd. v. PDIT (2021) 436 ITR 90 / 203 DTR 177/ (2023) 334 CTR 172 (Mad.)(HC)
S. 153C : Assessment-Income of any other person-Search-Service of notice-Notice without recording satisfaction is held to be not valid-Subsequent notice after valid satisfaction is held to be valid-High court can find out whether proper satisfaction is recorded or not, however cannot consider sufficiency of reasons [S. 132, 282, 282A Rule, 127, 127A, Art. 226]