Issuance of notice under section 148 was held incomplete unless the notice was dispatched and had gone beyond the issuing authority's control, and where service was by post the notice had to be properly addressed under section 27 of the General Clauses Act. Here, the original notice was sent to an incomplete address, returned, and only forwarded with the complete address after limitation had expired; the record also did not conclusively show when it was handed to postal authorities. On that footing, timely issuance was not proved, section 292BB could not cure the jurisdictional defect, and the reassessment proceedings were quashed as void ab initio.
Issuance of notice under section 148 was held incomplete unless the notice was dispatched and had gone beyond the issuing authority's control, and where service was by post the notice had to be properly addressed under section 27 of the General Clauses Act. Here, the original notice was sent to an incomplete address, returned, and only forwarded with the complete address after limitation had expired; the record also did not conclusively show when it was handed to postal authorities. On that footing, timely issuance was not proved, section 292BB could not cure the jurisdictional defect, and the reassessment proceedings were quashed as void ab initio.
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