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        Case ID :

        2026 (7) TMI 419 - AT - Income Tax

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        Digital signature date controls completion of assessment order, making a belatedly signed order time-barred and quashed. An assessment order is treated as complete only when it is digitally signed, even if it bears an earlier date on the face of the order. On the facts ...
                        Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

                            Digital signature date controls completion of assessment order, making a belatedly signed order time-barred and quashed.

                            An assessment order is treated as complete only when it is digitally signed, even if it bears an earlier date on the face of the order. On the facts noted, the order showed 30.04.2024 but was digitally signed on 01.05.2024, and the Tribunal applied the jurisdictional High Court view that the completion date is the date of digital signature. Because that date fell beyond the limitation period, the assessment was held time-barred and quashed. Once the assessment was quashed on limitation, the remaining grounds became infructuous and were not examined.




                            Issues: Whether the final assessment order was barred by limitation because it was complete only on the date it was digitally signed, and whether the assessment order was liable to be quashed on that ground.

                            Analysis: The order and portal record showed that although the assessment order bore the date 30.04.2024, it was digitally signed on 01.05.2024. Following the jurisdictional High Court's view that an order is complete only when digitally signed, the Tribunal held that the relevant date for completion was 01.05.2024. Since that date was beyond the limitation period, the assessment order could not be sustained. Once the assessment order was quashed, the other grounds did not survive for adjudication.

                            Conclusion: The assessment order was held to be time-barred and was quashed, resulting in relief to the assessee.


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                            ActsIncome Tax
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