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TMI Blog2025 (5) TMI 1073X X X X Extracts X X X X X X X X Extracts X X X X ..... M. R. Sahu, AR. For The Respondent : Shri Prathvi Raj Meena, CIT. DR ORDER PER SHRI NARENDRA PRASAD SINHA, AM: This appeal was originally decided vide order ITA No. 68/Ahd/2023 dated 20.05.2024 and the appeal of the assessee was dismissed. Thereafter, the assessee had filed a Miscellaneous Application on the ground that additional legal ground taken by the assessee were omitted to be adjudi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... by the assessee on this email address. He further submitted that the intimation sent by the department on any other email address was not a valid service of notice. 3. Per contra, Shri Prathvi Raj Meena, Ld. CIT.DR submitted that before processing return of income, a notice of adjustment u/s. 143(1)(a) of the Act was issued to the assessee on 23.03.2019, which was sent on the assessee's email ad ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itted that identical issue was involved in assessee's own case in A.Y. 2019- 20 reported in Checkmate Services (P) Ltd, vs. ADIT, CPC (164 taxmann.com 498) and the ITAT had held that the email address "[email protected]" belonged to the assessee and that a notice sent on this email address was valid communication. 4. We have considered the rival submissions. The contention of the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt intimation u/s. 143(1) of the Act sent to the assessee on this email address was duly received by the assessee, it cannot take a plea that the earlier notice for adjustment sent on this email address was not received. A copy of the notice dated 23.03.2019 for the proposed adjustment u/s 143(1)(a) of the Act has also been brought on record by the Revenue. Therefore, the contention of the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... case are identical to the facts of A.Y. 2019-20. Therefore, following the decision of the Co-ordinate Bench of the Tribunal for A.Y. 2019-20, we do not find an y merit in the ground taken by the assessee and the same is dismissed. 6. In the result, the additional legal ground taken by the assessee that no show cause notice regarding the proposed adjustments was issued to the assessee before passi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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