AO is circumscribed and bound by express mandate of Rule 127 (of Income Tax Rules, 1962).

Held Rule 127(2) (of Income Tax Rules, 1962) clearly stated that addresses to which a notice or summons or requisition or order or any other communication may be delivered or transmitted should be either available in assessee’s PAN database or address available in income tax return to which communication related or address available in last income tax return filed by assessee-all those options had to be resorted to by AO. When AO issued reassessment notice, he was under a duty to access available PAN data base of addressee or address available in income tax return to which communication related or address available in last income return filed by addressee. AO omitted to access changed PAN database and going by explanation of Revenue, he merely mechanically sent notices at old address. Even after issuing reassessment notice, all succeeding notice u/s 142(1) (of Income Tax Act, 1961), were sent to old address. (Para 5) AO was circumscribed and bound by express mandate of Rule 127 (of Income Tax Rules, 1962) which was clearly addressed to Revenue authorities vis-a-vis mode of communication. AO had completely and mechanically proceeded on information supplied to him by bank without caring to address himself to correct position in law and deduced to ensure that reassessment notice (which was a matter of moment as far as assessee was concerned) was issued properly and served at correct address in manner known to law. Assessee relied upon a screenshot of PAN database at stage when petition was filed to say that Revenue always had wherewithal to access correct address, PAN number and all other relevant details including email ID as well as bank account. Omissions of AO deserved, therefore, to be not only adversely noticed but appropriately reflected in his or her confidential reports and appropriate proceedings initiated by Revenue authorities, which was so directed. Concerned Commissioner, Principal Commissioner or other superior authorities, as case may be, were directed to file a report in this regard. (Paras 6 & 7)