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    <description>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.</description>
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