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HC held that the digital notice signed on 31.03.2021 but emailed and dispatched on 01.04.2021 did not vitiate reassessment proceedings under Section 147/149 of the Income Tax Act. The court determined that jurisdictional notice requirements were technically met, and subsequent steps taken by revenue authorities were valid. Despite potential procedural irregularities, the court dismissed the petitioner's challenge, affirming the reassessment proceedings as legally sustainable based on recent Supreme Court precedents regarding notice issuance and jurisdictional requirements.
HC held that the digital notice signed on 31.03.2021 but emailed and dispatched on 01.04.2021 did not vitiate reassessment proceedings under Section 147/149 of the Income Tax Act. The court determined that jurisdictional notice requirements were technically met, and subsequent steps taken by revenue authorities were valid. Despite potential procedural irregularities, the court dismissed the petitioner's challenge, affirming the reassessment proceedings as legally sustainable based on recent Supreme Court precedents regarding notice issuance and jurisdictional requirements.
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