Unsigned reassessment notices cannot confer jurisdiction, and the resulting reassessment order was quashed for fatal defect.

Unsigned reassessment notices and orders were treated as invalid where the notice under section 148A(b), the order under section 148A(d), and the notice under section 148 bore neither manual nor digital signature. The Tribunal applied the principle that an unsigned notice or order cannot validly confer jurisdiction to continue reassessment proceedings, and held the defect to be fatal. Because the foundational notices were invalid, the reassessment order based on them could not survive and was quashed, with the cross-objection allowed.

---

---

Issues: Whether reassessment notices and the consequential reassessment order were liable to be quashed for absence of manual or digital signature on the notice under section 148A(b), the order under section 148A(d), and the notice under section 148 of the Income-tax Act, 1961.

Analysis: The notices and the order placed on record were found to bear no manual or digital signature. Relying on the principle that an unsigned notice or order is invalid and cannot confer jurisdiction to proceed with reassessment, the Tribunal treated the defect as fatal to the reassessment proceedings. Once the foundational notices were held invalid, the assessment order based on them could not survive.

Conclusion: The reassessment notices and the assessment order were quashed, and the cross-objection was allowed.

---