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    <title>1985 (8) TMI 67 - PATNA High Court</title>
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    <description>Section 149 of the Income-tax Act, 1961 is satisfied by issuance of a reassessment notice within the prescribed period; actual service within that period is not required. The Court treated the use of &quot;issued&quot; as deliberate, distinguished older authorities under different wording, and held that reading a service requirement into the provision would defeat the limitation scheme in sections 148, 149 and 151. As the notice was validly issued in time, the reassessment was not barred by limitation, and the connected cancellation of penalty under section 271(1)(a) was also held unsustainable.</description>
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    <pubDate>Tue, 20 Aug 1985 00:00:00 +0530</pubDate>
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      <title>1985 (8) TMI 67 - PATNA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=26982</link>
      <description>Section 149 of the Income-tax Act, 1961 is satisfied by issuance of a reassessment notice within the prescribed period; actual service within that period is not required. The Court treated the use of &quot;issued&quot; as deliberate, distinguished older authorities under different wording, and held that reading a service requirement into the provision would defeat the limitation scheme in sections 148, 149 and 151. As the notice was validly issued in time, the reassessment was not barred by limitation, and the connected cancellation of penalty under section 271(1)(a) was also held unsustainable.</description>
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      <pubDate>Tue, 20 Aug 1985 00:00:00 +0530</pubDate>
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