IT : Where assessee challenged validity of reassessment proceeding on ground that service of notice by Inspector at factory premises on security guard was not proper service under provisions of section 282(2), in view of fact that assessee raised said plea of improper service of notice for first time before Tribunal and, moreover, in response to notice issued under section 148, one director of assessee-company had appeared before Assessing Officer, it could be concluded that provisions of sectio
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