https://www.taxtmi.com/caselaws?id=419746 Digitally signing a reassessment notice under section 148 does not by itself amount to issuance for limitation purposes under section 149. The statutory scheme requires issuance or electronic communication in the prescribed manner, and under the Information Technology Act an electronic record is dispatched only when it enters a computer resource outside the originator's control. On that basis, a notice sent by e-mail after the limitation period had expired was treated as time barred, because issuance was completed only on dispatch beyond the assessing authority's control. en-us Thu, 10 Mar 2022 00:00:00 +0530 Fri, 26 Dec 2025 15:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=419746 Digitally signing a reassessment notice under section 148 does not by itself amount to issuance for limitation purposes under section 149. The statutory scheme requires issuance or electronic communication in the prescribed manner, and under the Information Technology Act an electronic record is dispatched only when it enters a computer resource outside the originator's control. On that basis, a notice sent by e-mail after the limitation period had expired was treated as time barred, because issuance was completed only on dispatch beyond the assessing authority's control. Case-Laws Income Tax Thu, 10 Mar 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=419746