R.K.UPADHYAYA vs SHANABHAI P. PATEL

The Supreme Court held that the notice issued under Section 147(b) of the Income-tax Act, 1961 was valid as it was served within the limitation period. The Court vacated the Gujarat High Court's order which had quashed the notice on the grounds of limitation, affirming that timely service of notice is essential for the Income-tax Officer's jurisdiction to reassess. The judgment referenced the principles established in Banarsi Debi & Anr. v. I.T.O., 53 ITR 100 regarding the importance of notice issuance and service within the statutory timeframe.