1989 (5) TMI 42
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....e matter here pertains to limitation for reassessment, in pursuance of a notice under section 148 of the Income-tax Act, 1961, the point in issue being whether limitation is to be seen from the date of the issuance of the notice under section 148 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), or from the date when such notice is actually served upon the assessee ? What had ....
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.... controversy here now stands settled by the judgment of the Full Bench of this court in Jai Hanuman Trading Co. Pvt. Ltd. v. CIT [1977] 110 ITR 36, where it has been laid down that in the scheme of the Income-tax Act, 1961, limitation under section 149 of the Act has been prescribed with reference to the issuance of the notice and not its service upon the assessee. The earlier judgment of this ....
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