Unsigned income-tax notice invalidates assessment jurisdiction when the statute requires a signed notice

An unsigned and blank notice under section 143(2) was held invalid because section 282A(1) requires a notice issued by an income-tax authority to be signed, whether in paper form or electronically. The deeming authentication provision in section 282A(2) did not override that mandatory signature requirement. As the notice was not valid in law, it could not confer jurisdiction on the Assessing Officer to complete assessment under section 143(3), and the assessment based on it was quashed.

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Issues: Whether an unsigned and blank notice issued under section 143(2) was valid, and whether such invalidity deprived the Assessing Officer of jurisdiction to complete the assessment under section 143(3).

Analysis: The notice under section 143(2) was found to be left unsigned and blank. Section 282A(1) requires that a notice or other document issued by an income-tax authority shall be signed, whether issued in paper form or communicated electronically. The deeming authentication under section 282A(2) does not dispense with the mandatory requirement of signature under section 282A(1). As the notice was not signed, it was not a valid notice in law and could not confer jurisdiction for completion of assessment under section 143(3).

Conclusion: The unsigned notice was invalid and void ab initio, and the assessment framed on that basis was quashed in favour of the assessee.

Ratio Decidendi: A notice required by the Act must be signed as mandated by section 282A(1); an unsigned notice is invalid and cannot confer jurisdiction for assessment.

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