Reopening of assessment u/s 147 - period of limitation - Once...

Reopening of assessment u/s 147 - period of limitation - Once the notice under Section 148 of the Act is issued within the period of limitation by despatching the notice in the Post-Office, the same would be sufficient to meet out the requirements. Section 149 of the Act itself contemplates time limit for notice. - It is possible in many circumstances, the addressee may receive the cover one or two days later or on account of various other reasons, the postal department may deliver after three or four days and all these circumstances are possible. - Thus, the delivery of cover is immaterial - HC