Allowing the appeal of the assesesee the Tribunal held that ; reassessment notice under S. 148(1) was issued against assessee after expiry of period of limitation at old address of assessee which was already changed by assessee before date of issuance of said reassessment notice in official record by updating PAN data base, it could be said that there was no service of reassessment notice upon assessee. Accordingly reassessment proceeding is held to be bad in law .(AY.2009-10)
Ardent Steel Ltd. v. ACIT ( 2018) 405 ITR 422/ 302 CTR 362/166 DTR 33 (Chhattisgarh) (HC)
S.148: Reassessment-Notice -Issue of notice at old address after expiry of period of limitation ,in spite of change in the official record by updating PAN data base- Reassessment is held to be bad in law [ S.147 ,292BB ]