Reopening of assessment u/s 147 - Date of issuance of notice -...

Reopening of assessment u/s 147 - Date of issuance of notice - communication in electronic form - Whether digitally signing notice would automatically amount to issuance of notice ? - Whether digitally signing a notice and issuing it are two different acts ? - mere digitally signing the notice is not the issuance of notice. Since the impugned notice under Section 148 of the Act, 1961 was issued to the petitioner on 06.04.2021 through e-mail, therefore, we hold that the impugned notice under section 148 of the Act, 1961 is time barred. - HC