Limitation for reassessment turns on the signing date of the order, not the earlier date shown on its face.

Limitation for reassessment under Section 147 was governed by Section 153(2) read with Explanation 1 to Section 153, requiring exclusion of time spent on reference to the Valuation Officer under Section 142A. The decisive date was the Assessing Officer's receipt of the valuation report, not the report date itself; on the admitted facts, the report was received on 25 February 2022 and the sixty-day period expired on 26 April 2022. Although the order bore the date 13 April 2022, it was digitally signed only on 26 May 2022, and the date of preparation was treated as immaterial. The reassessment order was therefore barred by limitation and liable to be quashed.

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Issues: Whether the reassessment order under Section 147 of the Income-tax Act, 1961 was barred by limitation, having regard to the date on which the valuation report was received and the date on which the assessment order was digitally signed.

Analysis: The governing limitation under Section 153(2) read with Explanation 1 to Section 153 required exclusion of the period consumed by the reference to the Valuation Officer under Section 142A. The decisive factual question was the date of receipt of the valuation report by the Assessing Officer. On the Revenue's admitted position, the report dated 16 February 2022 was received on 25 February 2022, and the available sixty-day period for completing the assessment expired on 26 April 2022. The order, though bearing the date 13 April 2022, was digitally signed only on 26 May 2022. The date of preparation was held to be immaterial, and the assessment order was treated as operative only upon signing.

Conclusion: The reassessment order was barred by limitation and was liable to be quashed and set aside.

Ratio Decidendi: For limitation under reassessment provisions, the assessment order takes effect on the date it is signed, and not on the earlier date shown on the face of the order; if the signed order is beyond the statutory time limit, it is invalid.

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