- (1.) The proceedings relates to the assessment year 1996-97.
(2.) A notice under Section 148 of the Income Tax Act, 1961 (hereinafter referred to as the "Act") dated 16.10.2000 was issued to the respondent-assessee whereupon proceedings under Section 142 of the Act were initiated and the order of reassessment was passed.
(3.) The Commissioner of Appeals has held that the proceedings stand vitiated as the notice under Section 148 of the Act was not served upon the respondent-assessee. The aforesaid order has been upheld by the Tribunal.;