Unsigned section 151 approval invalidated the assessment where section 282A(1) signing requirements were not met.

An unsigned approval under section 151 was treated as invalid because section 282A(1) requires a notice or other document issued by an income-tax authority to be signed, including in electronic form. The defect was regarded as substantive rather than a mere irregularity, and the absence of a valid foundational approval deprived the assessment proceedings of jurisdiction. On that basis, the approval was held void ab initio and the resultant assessment was quashed.

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Issues: Whether an unsigned approval granted under section 151 of the Income-tax Act, 1961, is invalid for non-compliance with section 282A(1) of the Income-tax Act, 1961, and whether such defect vitiates the subsequent assessment.

Analysis: The approval under section 151 was found to be unsigned. 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 defect was treated as substantive and not a mere irregularity, and the consequent assessment proceedings were held to lack valid jurisdiction once the foundational approval was invalid.

Conclusion: The unsigned approval under section 151 was invalid and void ab initio, and the resultant assessment was quashed.

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