Dismissing the petition the Court held that the limitation period for reassessment is to be reckoned from date of issue of notice and not from service of notice. Court also observed that meaning of service by post as defined under section 27 of the General Clauses Act , 1897 may not have any applicability or relevancy as far as section 149 of the Income -tax Act , 1961 .
Sadhna Tolasariya v. ITO (2021) 202 DTR 377/ 281 Taxman 354/ 328 CTR 721 (Mad.) ( HC)/Laxmi Kanta Talasaiya v. ITO 2021) 202 DTR 377 / 328 CTR 721 ( Mad ) (HC)/Praveen Amin Bhathara (Smt) v. ITO ( 2021) 202 DTR 377 / 328 CTR 721 ( Mad ) (HC) Rjesh Gupta v ITO ( 2021) 202 DTR 377 ( Mad ) (HC)
S. 149 : Reassessment – Time limit for notice – From the date of issue of notice and not from service of notice- Writ petition was dismissed . [ S. 147, 148 , 281, Art , 226, General Clauses Act , 1897 , S. 27 ]