Unsigned Section 148 notice invalidates reassessment where no signature defect is cured or disputed.

An unsigned notice issued under Section 148 of the Income-tax Act was treated as invalid because it was neither digitally signed nor physically signed by the Assessing Officer, and the Department produced no material to cure or dispute the defect. The jurisdictional challenge was admitted as it went to the root of validity. As the notice was held void, the foundation for reassessment under Section 147 read with Section 148 was absent, and the reassessment proceedings could not survive.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961, being unsigned, was valid and whether the reassessment proceedings initiated on that basis could survive.

Analysis: The additional legal ground challenging the validity of the notice was admitted as it went to the root of jurisdiction. The notice produced on record was found to be neither digitally signed nor physically signed by the Assessing Officer. No material was placed by the Department to controvert this defect. In these circumstances, the notice under Section 148 was treated as invalid, and the foundation for proceedings under Section 147 read with Section 148 was held to be absent.

Conclusion: The notice under Section 148 was held invalid, the reassessment proceedings could not survive, and the appeal succeeded on the jurisdictional ground.

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