The assessee participated in the assessment proceedings . However , the assessee challenged the notice under sections 143(2) and 142(1) of the Act on the ground that the said notrices were not served upon the assessee as the assessee company never received those notrices and subsequent notices served and received by the compoany were beyond the period of limitation prescribed under proviso to S.143 of the Act. The AO has not accepted the contention of the assessee. On appeal the CIT (A) held that the order is bad in law , however the appeal was not decided on merits as regards the merits of the addition. Order of CIT (A) is affirmed by the Tribuanl and High Court. On appeal by the revenue   allowing the appeal o the Court held that,  mere mentioning of new address in the return of income is not enough.If change of address is not specifically intimated to the AO, he is justified in sending the notice at the address mentioned in PAN database. If the notice is sent within the period prescribed in S. 143(2), actual service of the notice upon the assessee is immaterial. Order of High Court and Tribunal is set aside and CIT (A) is directed to decide the appeal on merits on other grounds . ( AY. 2006 -07) ( CA No.8132 of  2019, dt. 18.10.2019)