Reassessment limitation runs from issuance of notice, not service, so a timely notice remains valid despite late service.

Limitation for reassessment under the Income-tax Act is computed from the date of issuance of notice under section 148, not from the date of service on the assessee. A notice issued within the prescribed period remains valid even if served after limitation expires. The Tribunal was therefore wrong in treating the reassessment as time-barred solely because service occurred late, and the issue was answered in favour of the Revenue.

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Issues: Whether limitation for reassessment under the Income-tax Act is to be reckoned from the date of issuance of notice under section 148 or from the date of service of such notice on the assessee.

Analysis: The controlling rule was settled by the Full Bench decision that, in the scheme of the Income-tax Act, limitation under section 149 is linked to the issuance of notice and not its service. On that construction, a notice issued within the prescribed period remains valid even if it is served after the limitation period has expired.

Conclusion: The Tribunal was not right in treating the reassessment as time-barred merely because service of the notice occurred after the expiry of limitation. The answer was given in the negative, in favour of the Revenue and against the assessee.

Ratio Decidendi: For reassessment proceedings, the relevant date for limitation is the date of issuance of notice under section 148, not the date of service of that notice.

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