Mahabir Singh Joon v. ITO (2024)467 ITR 664 (Delhi)(HC)

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Service of notice on address given by assessee and delivery report received-Service of notice is valid. [S. 148, 148A(b), 148A(d), Art. 226]

Held, that what was sought to be contended was that the service of the notice was not effected through e-mail. That was not the mandate of section 148A(b) of the Act. The Revenue had countered the version of the assessee by placing on record the delivery report at the address of the assessee. There was no quarrel regarding the address on record or the delivery report. The requirement of natural justice stood fulfilled once the notice was served at the admitted address of the assessee. The service of notice is  valid.  Writ petition is dismissed. (AY. 2016-17)