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2010 (8) TMI 66 - DELHI HIGH COURT
Reassessment - serving of a notice - AO noted that the assessee company had made disclosure of income under the VDIS, 1997. The assessee failed to deposit the taxes in accordance with the VDIS and, therefore, the declaration was held to be void in terms of Section 67(2) of the Scheme. Notices under Section 148 of the Act were issued on 24.12.1999 - Held that: - the issue was raised on an earlier occasion before the CIT(A) who after scanning the factual matrix in detail, expressed the view that the notice was served on the assessee. The said finding was affirmed by the tribunal. Service of notice or non-service of notice is in the realm of facts and as a matter of fact it was put to rest. Thus, it does not give rise to a total pure question of law. Thus, the said decision is distinguishable. - notice service through registered post is presumed to be served unless contrary proved by the assessee