Supreme Court : [Favore of Revenue] Service of notice is not a condition precedent to conferment of jurisdiction in ITO but it is a condition precedent to making of order of assessment .

Shanabhal P. Patel R.K. Upadhaya SUPREME COURT 

166 ITR 163
33 Taxman 229

[ Decision year 1987] [AY 1963-64 , May be as notice u./s 147 is to serve written as 31.03.1970, Six Year]

Service of notice is not a condition precedent to conferment of jurisdiction in ITO but it is a condition precedent to making of order of assessment .