BANARASI DEVI vs INCOME-TAX OFFICER, CALCUTTA

The Supreme Court interpreted Section 4 of the Income-tax (Amendment) Act, 1959, clarifying that the term 'issued' encompasses both the sending and serving of notices. The Court held that notices served beyond the prescribed time could still be valid if they were issued within the time limit, thereby allowing the Income-tax Officer to reassess income that had escaped assessment. The judgment emphasized that the general rules of construction applicable to fiscal statutes should be applied, affirming the validity of the notices and assessments despite the timing of their service.