Assessing Officer issued reopening notice under section 148A(b) alleging that assessee, a Singaporean company, had received a certaiti sum on ae count of FTS/FIS from Indian company on which TDS was not deducted by Indian payer even though consideration received by assessee was income chargeable to tax which had escaped assessment. On writ the assessee contended that   it was registered in Singapore and had no Permanent Account Number, nor any credentials in Income-tax Portal apart from not having received any commu nication whatsoever at Singapore.Court held that   revenue had not been able to demonstrate that reopening notice under section 148A(b) was ever served upon assessee at its registered office in Singapore and fact that assessee had no Permanent Account Number nor any credentials in IT Portal had neither been contradicted nor controverted by revenue. Matter was remanded back to the stage of considertation notices under section 148A(b) of the Act. (AY. 2019 -20)