Electronic reassessment notice issuance turns on digital signing date, triggering the amended reopening regime and invalidating old-procedure action.

An electronically generated reassessment notice under section 148 is issued only when it is validly signed and communicated, so a notice dated 31.03.2021 but digitally signed on 01.04.2021 was treated as issued on 01.04.2021. That effective date brought the matter within the substituted reassessment regime, requiring compliance with the amended procedure in force from 01.04.2021. Because the reopening was pursued under the pre-amendment framework instead of the post-amendment mechanism, the reassessment could not be sustained. The Tribunal followed the Supreme Court's approach that such notices must be examined under the governing amended framework applicable on the actual date of issuance.

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Issues: Whether the reassessment notice under section 148 of the Income-tax Act, 1961, bearing the date 31.03.2021 but digitally signed on 01.04.2021, was to be treated as issued on 01.04.2021 so that the reassessment had to proceed under the substituted regime and not under the pre-amendment provisions.

Analysis: The notice could not be regarded as issued before it was digitally signed and transmitted. On the facts, the digital signature on 01.04.2021 fixed the point of issuance, and the notice therefore fell after the coming into force of the substituted reassessment scheme. Once so treated, the reassessment could not be sustained on the basis of the old provisions. The absence of compliance with the post-amendment procedure, including the statutory mechanism applicable from 01.04.2021, rendered the reopening unsustainable. The Tribunal also followed the governing Supreme Court position that such pre-amendment notices are to be dealt with under the amended framework.

Conclusion: The reassessment notice was validly treated as issued on 01.04.2021 and the Revenue's challenge failed; the finding quashing the reassessment was upheld.

Ratio Decidendi: For an electronically generated reassessment notice, issuance occurs only upon valid signing and communication, and the applicable reassessment regime is determined by that effective date.

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