Affirming the order of the Tribunal the Court held that  no notice was ever served upon the registered address of the assessee company nor sent through the registered post or speed post nor any efforts were made to serve the notice through affixture. Despite raising objection even, copy of notice u/s 148 was not served upon the assessee. The claim of Department of service of notice on the Advocate / CA, or an employee not authorized by the assesse company, cannot be accepted, hence there was no valid service effected as per Section 282 of the Act read with Order 5 CPC,1908. The High Court further held that the Tribunal has correctly observed as held by Delhi High Court in the case of CIT vs. Chetan Gupta (2015) 126 DTR (DEL) 401 that Section 292B of the Act, which was inserted in the 2008, cannot be given a retrospective effect. No question of law arose hence, the appeal was dismissed.