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Section 148 of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for Where no evidence in shape of postal receipt was produced by revenue to show that actually reassessment notice was sent by registered post and was served upon assessee, reassessment proceedings were not valid. [A.Y. 1998-99]. The Commissioner (Appeals) held that the assumption of jurisdiction by the Assessing Officer to reassess was wrong as there was no service of notice under section 148. The Tribunal upheld order of the Commissioner (Appeals). On appeal, the revenue submitted that notice under section 148 was sent to the assessee through registered post and therefore, the same tantamounted to a valid service as per section 27 of the General Clauses Act, 1897. Held that no evidence in the shape of postal receipt was produced by the revenue to show that actually, the reassessment notice was sent registered post and was served upon the assessee. The Commissioner (Appeals) as well as the Tribunal had recorded a pure finding of fact, after considering the material available on record, to the effect that notice under section 148 was actually not served upon the assessee, which was a condition precedent for making reassessment or recomputation under section 147. Therefore, the reassessment proceedings were not valid. Sanjiv Bansal for the Appellant. JUDGMENT Satish Kumar Mittal, J.-The instant appeal filed by the Revenue under section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), is directed against the order dated April 13, 2007, passed by the Income-tax Appellate Tribunal, Chandigarh Bench "A", Chandigarh (hereinafter referred to as "the Tribunal"), in I. T. A. No. 181/Chandi/2006 in the case of the respondent for the assessment year 1998-99, by raising the following substantial questions of law : "(i) Whether, on the facts and in the law, the Tribunal was justified in holding that reassessment has been made without mandatory requirement of service of notice under section 148 of the Act, by ignoring the fact that notice issued on March 30, 2001, within the limitation under section 149(1) of the Act was sent through registered post, which…

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