Electronic reassessment notice issuance turns on dispatch beyond the officer's control, not the date printed on the notice.

For electronically transmitted reassessment notices, "issue" under Section 149 of the Income-tax Act is complete only when the notice is dispatched into a computer resource outside the Assessing Officer's control under Section 13(1) of the Information Technology Act. A notice merely bearing an earlier date is insufficient if the electronic record shows transmission after the limitation cutoff, and limitation provisions in tax matters require strict compliance. On the facts recorded, the notice was sent and delivered after midnight on 1 April 2021, so it was time-barred and invalid; the consequential reassessment action could not stand.

---

---

Issues: Whether the notice under Section 148 of the Income-tax Act, 1961 reopening the assessment for assessment year 2014-15 was issued within the limitation period prescribed by Section 149(1) of the Income-tax Act, 1961, having regard to the time of electronic dispatch under Section 13(1) of the Information Technology Act, 2000.

Analysis: The reassessment notice was dated 31.03.2021, but the department's electronic record showed that it was sent on 01.04.2021 at 3:58:33 a.m. and delivered on 01.04.2021 at 3:58:36 a.m. The question turned on the meaning of "issue" in Section 149(1) of the Income-tax Act, 1961. Applying the statutory scheme and the principle that limitation provisions in taxing statutes must be strictly complied with, the Court held that when a notice is transmitted electronically, issuance is complete only when it enters a computer resource outside the control of the originator, as contemplated by Section 13(1) of the Information Technology Act, 2000. The signed date on the notice alone was insufficient, and there was no material to show that the notice had been put into the system on 31.03.2021.

Conclusion: The notice was not issued within time and was invalid.

Final Conclusion: The reassessment notice was quashed and the consequential assessment orders could not survive, with the petition being allowed.

Ratio Decidendi: For electronically transmitted reassessment notices, "issuance" for the purpose of Section 149 of the Income-tax Act, 1961 occurs only when the notice is dispatched into a computer resource outside the control of the Assessing Officer, as governed by Section 13(1) of the Information Technology Act, 2000.

---