Timely issue of reassessment notice satisfies limitation even if service later fails or the notice is returned undelivered.

For reassessment proceedings, limitation is satisfied when the notice is actually issued within the prescribed period, even if later postal tracking shows delayed booking or the notice is returned undelivered. The Court relied on the documentary record showing that the section 148 notice was signed and dispatched on 30.06.2025 with a postal seal of the same date, and treated timely issue as the ative requirement rather than completed service. Later service-related defects did not defeat jurisdiction where issuance within time was proved, and the writ petitions were dismissed.

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Issues: Whether the reassessment notice was validly issued within limitation where the notice was signed and dispatched on 30.06.2025, but the postal tracking reflected later booking and the notice was ultimately returned undelivered.

Analysis: The Court found, on the documentary record, that the notice under section 148 of the Income-tax Act, 1961 was issued on 30.06.2025 and bore the postal seal of dispatch on the same date. Relying on the principle that the relevant requirement for limitation is the issue of notice, and not its service, the Court applied the rule that once a notice is issued within time, the jurisdiction to proceed is not defeated by later service-related difficulties. The discrepancy in postal tracking and the return of the notice did not negate timely issuance.

Conclusion: The notice was held to have been validly issued within limitation, and the writ petitions were dismissed.

Ratio Decidendi: For reassessment proceedings, limitation is satisfied by the timely issue of notice; subsequent failure or delay in service does not invalidate a notice that was actually issued within the prescribed period.

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