Dy. CIT v. Taureg Properties and Security Services Ltd (2020)80 ITR 386 ( Delhi) (Trib)

S.148: Reassessment — Notice — Assessing Officer not signing notice or mentioning assessment year — Notice is illegal — Reassessment proceedings not valid .[ S.147]

Tribunal held that the notice of reassessment was unsigned and did not mention any assessment year. Since an unsigned notice had been sent to the assessee, it vitiated the entire reassessment proceedings because it was the jurisdictional notice to initiate proceedings under section 147 of the Income-tax Act, 1961 . Since the notice itself was illegal and bad in law, the entire reassessment proceedings were vitiated and the Assessing Officer could not have assumed jurisdiction under section 148 to frame the assessment against the assessee.( AY.2000-01)