Unsigned section 143(2) notice cannot confer jurisdiction for assessment; signature requirement under section 282A is mandatory.

An unsigned and blank notice issued under section 143(2) of the Income-tax Act was invalid because section 282A(1) makes signature mandatory for notices, whether in paper form or electronic communication. The deeming rule in section 282A(2), which permits authentication by printing or stamping the name and office of the designated authority, does not remove the signature requirement. As a result, an invalid section 143(2) notice cannot furnish the jurisdictional basis for assessment proceedings under section 143(3), and the assessment framed on that notice was quashed.

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Issues: Whether an unsigned and blank notice issued under section 143(2) of the Income-tax Act, 1961 was valid and capable of conferring jurisdiction to complete assessment under section 143(3) of the Income-tax Act, 1961.

Analysis: The notice was found to be left unsigned and blank. Section 282A(1) of the Income-tax Act, 1961 makes signature of the notice mandatory, whether the notice is issued in paper form or communicated electronically. The deeming provision in section 282A(2) concerns authentication by printing or stamping of the name and office of the designated authority and does not dispense with the requirement of signature under section 282A(1). An invalid notice under section 143(2) cannot serve as the jurisdictional foundation for assessment proceedings under section 143(3).

Conclusion: The notice under section 143(2) of the Income-tax Act, 1961 was invalid, void ab initio, and incapable of conferring jurisdiction; the assessment framed under section 143(3) of the Income-tax Act, 1961 was therefore quashed in favour of the assessee.

Ratio Decidendi: A notice required by the Act must be signed as mandated by section 282A(1) of the Income-tax Act, 1961, and an unsigned notice under section 143(2) is invalid and cannot confer jurisdiction for assessment under section 143(3).

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