S. 148 : Reassessment – Notice – Valid service of notice is not mere procedural requirement , it is a condition precedent to validity of any assessment or reassessment – If notice issued is shown as invalid , subsequent proceedings shall be illegal – Service by affixture – Reassessment was quashed as the service of notice was not proper as per the law as per Order V, Rule 12, Rule 17, rule 19, Rule 20(1) and Order III, Rule 2 of the Code of Civil Procedure 1908 . [ S. 147, 149, 282 ]
K.P. Cold Storage v .ITO ( 2019 ) 201 TTJ 649/ ( 2020) 189 DTR 385 (Agra)(Trib)