Electronic scrutiny assessment must bear digital signatures; a manually signed order in breach of procedure was quashed.

Where scrutiny assessment is conducted through e-proceedings, the assessment order must comply with the mandatory digital-signature procedure prescribed in CBDT Instruction No. 1/2018. A manually signed order, issued without any shown exception to that requirement, constitutes a procedural defect going to the validity of the assessment. On that basis, the assessment was quashed and the assessee's additional ground was allowed; the remaining grounds became academic.

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Issues: Whether the assessment was liable to be quashed because the scrutiny proceedings were conducted through e-proceedings but the final assessment order was signed manually in breach of CBDT Instruction No. 1/2018.

Analysis: The assessment was completed through the electronic scrutiny mechanism. The applicable CBDT instruction required departmental orders and communications issued through e-proceedings to be signed digitally, and no exception permitting manual signature was shown. The manual signing of the assessment order in an electronic assessment was treated as a violation of the prescribed procedure and, following the coordinate bench view relied upon, as a defect going to the validity of the assessment.

Conclusion: The assessment was held to be invalid and was quashed; the additional ground was allowed in favour of the assessee.

Final Conclusion: The appeal succeeded because the assessment order could not survive the procedural defect in its issuance, and the remaining grounds became academic.

Ratio Decidendi: Where scrutiny assessment is conducted electronically, the assessment order must comply with the prescribed digital-signature procedure, and a manually signed order issued in breach of that mandatory requirement is liable to be quashed.

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