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of The HC quashed a Section 148 notice for reassessment as it was issued beyond the statutory six-year limitation period. The revenue contended the notice dated 31.3.2021 was validly issued within time, but the departmental screenshot showed the email was sent on 01.04.2021 at 03:58:33 AM with delivery occurring within three microseconds. Despite the assessing officer's signature timestamp of 31.3.2021 at 18:36 PM, the court held that the actual system dispatch time was determinative. The revenue failed to provide evidence that the notice was placed in the system on 31.3.2021, and their plea regarding traffic congestion was rejected due to lack of supporting material. The petition was allowed, and the reassessment notice was quashed for being time-barred.
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