Limitation period for reassessment to be reckoned from date of ‘issue of notice’ amp; not from ‘service of notice’: HC

INCOME TAX: 'Issue of Notice' by Competent Authority is contemplated under section 149. However, 'Service of Notice' to assessee has not been contemplated under said provision. Thus, 'time limit' prescribed for 'issue of notice' under section 148 , would not fall under definition of 'service' under section 27 of General Clauses Act, 1897. Thus, section 27 of General Clauses Act, 1897 may not have relevance with reference to sections 147, 148 and 149.

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