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2020 (4) TMI 233 - HC - Income TaxReopening of assessment u/s 147 - no service of notice u/s 148 - HELD THAT:- None of the notices were returned by the postal authorities as unserved for want of complete or correct address the presumption of bonafide as obtaining in favour of the State would hold the ground. In any case, the appellant has received the notices sent by the Ld. AO on that same address as late as May 2017 and it cannot claim that the address was incorrect or incomplete. In view of the admission of the appellant the claim of the appellant that it did not receive the notices issued by the Ld. AO because of the address on which the said notices were sent by the Ld. AO was either incomplete or incorrect is not tenable Whether additional/fresh evidence was taken into consideration by the Commissioner of Income Tax (Appeals)? - HELD THAT:- AO by its report dated 26.03.2018 submitted its response to the fresh evidence of the appellant and rejected the same and recommended that the grounds raised by the appellant were neither maintainable nor acceptable in the eyes of the law and the appeal of the appellant deserved to be dismissed by this office. No substantial question(s) of law
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