The assessee challenged the reassessment on the ground that notice under section 148 dated 27-03-2019 was never validly served. The notice sent to the Bandra address remained unserved and the subsequent affixture was made on a locked room at Sonam Apartment, Bhiwandi, without any material establishing that the assessee resided, carried on business or had any connection with the premises. The Department’s own record indicated that the assessee did not reside there. It was only when the correct Vile Parle address and email were subsequently traced that the final show-cause notice dated 22-11-2019 was actually delivered, to which the assessee immediately responded and objected to the disputed PAN and earlier proceedings. The Tribunal held that affixture at an unrelated premises could not constitute valid service and that the objection raised before completion of assessment attracted the proviso to section 292BB. In the absence of valid service of the jurisdictional notice under section 148, the Assessing Officer could not assume jurisdiction to complete the reassessment under section 147. The assessment under section 144 read with section 147 was accordingly quashed and the additions of Rs.1,27,62,500 under section 69C and Rs.18,85,000 under section 68 could not survive..(AY. 2012-13) (ITA No. 1799/Mum/2025 dt. 21-09-2026)