https://www.taxtmi.com/caselaws?id=766433 An electronically generated reassessment notice under section 148 is issued only when it is validly signed and communicated, so a notice dated 31.03.2021 but digitally signed on 01.04.2021 was treated as issued on 01.04.2021. That effective date brought the matter within the substituted reassessment regime, requiring compliance with the amended procedure in force from 01.04.2021. Because the reopening was pursued under the pre-amendment framework instead of the post-amendment mechanism, the reassessment could not be sustained. The Tribunal followed the Supreme Court's approach that such notices must be examined under the governing amended framework applicable on the actual date of issuance. en-us Fri, 21 Feb 2025 00:00:00 +0530 Tue, 25 Feb 2025 08:24:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766433 An electronically generated reassessment notice under section 148 is issued only when it is validly signed and communicated, so a notice dated 31.03.2021 but digitally signed on 01.04.2021 was treated as issued on 01.04.2021. That effective date brought the matter within the substituted reassessment regime, requiring compliance with the amended procedure in force from 01.04.2021. Because the reopening was pursued under the pre-amendment framework instead of the post-amendment mechanism, the reassessment could not be sustained. The Tribunal followed the Supreme Court's approach that such notices must be examined under the governing amended framework applicable on the actual date of issuance. Case-Laws Income Tax Fri, 21 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766433