1989 (5) TMI 42

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..... ce 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 happened in this case was that with regard to the assessment year 1960-61, not .....

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..... ourt 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 court in Tikka Khushwant Singh case [975] 101 ITR 106 was specifically overruled. .....

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