Reassessment notice validity fails where post-2021 procedure, proper signature, and prescribed service requirements are not met.

A reassessment notice issued after 1 April 2021 had to comply with the substituted procedure under section 148A before proceedings could validly continue, and the notice failed that requirement because no notice under section 148A(b) and no order under section 148A(d) had been passed. The notice was also unsigned and was not served on the assessee's registered email ID, so issuance was not legally effective under sections 282 and 282A read with section 13 of the Information Technology Act, 2000. On that basis, the reassessment was initiated and completed contrary to mandatory procedure, and the reopening challenge succeeded.

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Issues: Validity of reassessment where the notice under section 148 of the Income-tax Act, 1961 was issued after 01.04.2021 without following the amended procedure under section 148A, without proper signature on the notice, and without service on the registered email ID of the assessee.

Analysis: The notice was treated as having been issued after the Finance Act, 2021 regime came into force, and therefore the reassessment machinery could operate only if the statutory preconditions under section 148A were complied with. The notice was found to be defective because no notice under section 148A(b) and no order under section 148A(d) had been passed. The notice also lacked the Assessing Officer's signature, and the notices were not served on the registered email address. Reading sections 282 and 282A of the Income-tax Act, 1961 with section 13 of the Information Technology Act, 2000, issuance required proper signing and due dispatch or communication; mere generation or digital preparation was not enough. In these circumstances, the reassessment was held to have been initiated and completed contrary to the mandatory statutory procedure.

Conclusion: The reassessment notice and the resulting assessment were invalid, and the challenge to reopening succeeded in favour of the assessee.

Ratio Decidendi: A reassessment notice issued after the commencement of the amended regime must strictly comply with the substituted reassessment procedure, and valid issuance requires proper signing as well as legally effective dispatch or service in the prescribed mode.

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