Mandatory signature requirement for tax notices invalidates unsigned notices and nullifies consequent reassessment proceedings under income tax law.

Unsigned notices or approvals required to be signed under Section 282A(1) of the Income-tax Act, 1961, lack the mandatory authentication and are therefore void; the deeming provision for printed or stamped names does not cure absence of the required signature. The absence of the signature constitutes a jurisdictional defect that cannot be remedied as a clerical mistake, and any proceedings founded on such invalid foundational notices, including reassessment proceedings under Section 147 read with Section 144B, consequently lack legal sustenance and are quashed.

---

---

Issues: Whether an unsigned notice/approval issued in electronic or paper form, in violation of Section 282A(1) of the Income-tax Act, 1961, is invalid and, if so, whether consequential reassessment proceedings under Section 147 read with Section 144B of the Income-tax Act, 1961, must be quashed.

Analysis: Section 282A(1) mandates that notices or documents required by the Act shall be signed and issued in paper form or communicated in electronic form in accordance with prescribed procedure. Section 282A(2) contains a deeming authentication where name and office are printed or stamped, but that deeming provision does not negate the mandatory signing requirement in clause (1). Where a notice or approval mandated to be signed is left unsigned, the issuing authority lacks the requisite authenticating act required by Section 282A(1). Jurisprudence and the statutory scheme treat absence of the mandatory signature as a jurisdictional defect that cannot be cured under provisions addressing clerical mistakes or omissions. If the foundational notice/approval is invalid for want of signature, any subsequent proceedings predicated on that notice/approval, including reassessment proceedings under Section 147 read with Section 144B and related provisions, lack legal sustenance.

Conclusion: The unsigned notice/approval violated Section 282A(1) of the Income-tax Act, 1961, and is invalid; consequently, the reassessment proceedings under Section 147 read with Section 144B of the Income-tax Act, 1961, are quashed. The appeal is allowed in favour of the assessee.

Ratio Decidendi: Where a notice or approval required to be signed by an income-tax authority is issued without the mandatory signature in breach of Section 282A(1) of the Income-tax Act, 1961, the notice/approval is void ab initio and vitiates any subsequent proceedings founded upon it.

---