Unsigned reassessment notice invalidated where the served copy differed from the signed record copy, quashing proceedings.

A reassessment notice under section 148 uploaded on the assessee's portal was unsigned, while the Revenue relied on a signed copy from the assessment record. Both carried the same DIN, but the discrepancy between the served notice and the record copy was not explained. Because the notice was the foundational jurisdictional document for reassessment, its validity was necessary to sustain the proceedings. The unsigned notice served on the assessee was treated as invalid, and the consequential reassessment was quashed.

---

---

Issues: Whether the notice issued under section 148 of the Income-tax Act, 1961, as received on the assessee's portal without a signature, was valid and whether the reassessment proceedings based on it could survive.

Analysis: The notice uploaded on the assessee's portal was found to be unsigned, while the Revenue produced a physically signed copy from the assessment records. Both versions bore the same DIN, but the discrepancy between the unsigned notice served to the assessee and the signed notice on record was not explained. Since the reassessment notice was the foundational jurisdictional document, its validity was essential to sustain the ensuing proceedings.

Conclusion: The unsigned notice served to the assessee was held invalid, and the consequential reassessment assessment was quashed.

---