The Tribunal held that the jurisdiction to assess or reassess is assumed on the issue of a notice under section 148(1), and not on its service. The time limit under section 149 is again with reference to the issue of notice under section 148, and not its service. There was no dispute qua the issue of notice under section 148(1) and jurisdiction to proceed to assess under section 147 had been validly assumed in the instant case.  Address shown on Permanent Account Number database at relevant time mentioned in memorandum of  appeal and even replies furnished during appellate proceedings, no satisfactory explanation for claim that notice was  sent to wrong address.  (AY.  2005-06)