Banarsi Debi v. ITO
53 ITR 100Supreme Court of India1964#1801 most cited
What is Banarsi Debi v. ITO authority for?
For income-tax notices, particularly under Section 34(1) of the 1922 Act (corresponding to Sections 147/148 of the 1961 Act), there is no real distinction between the 'issue' and 'service' of a notice. The word 'issued' must be given a wider meaning, effectively encompassing 'served'.
63
judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2011 to 2025.
Also referred to as
Banarsi Debi v. ITO · Section 34(1) 1922 Act · Section 147 · Section 148 · issue of notice · service of notice · meaning of 'issued' · validity of reassessment notice · no distinction between issue and service · 53 ITR 100 SC · income tax notice