E-notice issuance under Section 148 and digital signing timing prompted interim stay of reassessment proceedings pending detailed review.

Writ petitions challenging e-notices under Section 148 of the Income-tax Act raised issues on when a reassessment notice is treated as issued, dispatched and served where digital signing, sending and receipt straddle 31 March 2021 and 1 April 2021. The order noted that mere digital signing is not necessarily issuance, and that the timing of the electronic record entering the system outside the originator's control may be relevant. Because the notices fell into different date-based categories and required detailed examination, the Court recorded that an immediate final decision was not feasible before the assessment deadline in most cases and granted interim protection by staying proceedings under the impugned notices till further orders.

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Issues: Whether the batch of writ petitions concerning e-notices under Section 148 of the Income-tax Act, 1961 required detailed examination in light of the timing of issuance, dispatch and service of the notices, and whether interim protection should be granted pending final adjudication.

Analysis: The order noted multiple categories of notices based on whether they were dated on or before 31 March 2021, digitally signed before or after 1 April 2021, and sent or received after that date. It also noticed the view expressed in the cited judgment that mere digital signing is not issuance of notice and that the time of entry of the electronic record outside the control of the originator is relevant. In view of these considerations, the Court recorded that the matters required detailed examination and that an immediate judgment was not feasible before the assessment deadline in most cases.

Outcome: Proceedings pursuant to the impugned reassessment notices were stayed till further orders.

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