Digital-signature requirement in e-proceeding scrutiny assessments: manually signed assessment order quashed for non-compliance.

Scrutiny assessment completed through the e-proceeding facility must comply with the CBDT instruction requiring departmental orders to bear a digital signature. A manually signed assessment order, where no exception is shown for deviation from the prescribed electronic procedure, is invalid and liable to be quashed. The Tribunal held that non-compliance with the mandatory e-proceeding requirement vitiated the assessment, and the assessee succeeded on the additional ground.

---

---

Issues: Whether an assessment order passed in scrutiny proceedings conducted through e-proceedings is invalid when it is not digitally signed by the Assessing Officer in terms of CBDT Instruction No. 1/2018.

Analysis: The assessment was completed electronically, and the order was found to have been signed manually rather than digitally. The Tribunal noted that CBDT Instruction No. 1/2018 requires departmental communications and orders issued through the e-proceeding facility to bear digital signature, and no exception was shown to justify manual signing. Following the coordinate Bench decision relied upon, the Tribunal held that non-compliance with the prescribed e-proceeding procedure vitiated the assessment.

Conclusion: The assessment order was invalid for want of digital signature and was quashed, with the assessee succeeding on the additional ground.

Ratio Decidendi: Where scrutiny assessment is conducted through the e-proceeding facility, the Assessing Officer must comply with the mandatory digital-signature requirement prescribed by CBDT instructions, and a manually signed assessment order is liable to be quashed.

---