Digitally signed letter with computer-generated DIN cures procedural defects in reassessment order; writ jurisdiction not for document re-examination

Reassessment order initially lacked a DIN, attachments and bore a handwritten signature, but the defect was later cured by issuance of a digitally signed letter with a computer-generated DIN and letter number. SC held that it is not appropriate in writ jurisdiction to re-examine the nature of information or documents available to the assessing officer; the High Court had considered relevant aspects. The Court left open the legal questions for determination before the appropriate appellate authority and disposed of the petitions.

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Summary: The Court heard counsel and noted that the High Court "has considered all the relevant aspects of the matter threadbare." However, the Court expressly left the substantive issue unresolved, stating that "the question of law, is kept open for the petitioner(s)-assessee to be raised before the Appellate Authority in accordance with law." Consequently, "these petitions stand disposed of," and any "pending application(s), if any, stands disposed of." The operative legal outcome: factual and procedural findings by the High Court remain undisturbed for present purposes, while the legal question may be pursued before the appropriate Appellate Authority in accordance with law.

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