https://www.taxtmi.com/caselaws?id=773657 For electronically transmitted reassessment notices, "issue" under Section 149 of the Income-tax Act is complete only when the notice is dispatched into a computer resource outside the Assessing Officer's control under Section 13(1) of the Information Technology Act. A notice merely bearing an earlier date is insufficient if the electronic record shows transmission after the limitation cutoff, and limitation provisions in tax matters require strict compliance. On the facts recorded, the notice was sent and delivered after midnight on 1 April 2021, so it was time-barred and invalid; the consequential reassessment action could not stand. en-us Mon, 05 May 2025 00:00:00 +0530 Thu, 26 Jun 2025 08:35:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773657 For electronically transmitted reassessment notices, "issue" under Section 149 of the Income-tax Act is complete only when the notice is dispatched into a computer resource outside the Assessing Officer's control under Section 13(1) of the Information Technology Act. A notice merely bearing an earlier date is insufficient if the electronic record shows transmission after the limitation cutoff, and limitation provisions in tax matters require strict compliance. On the facts recorded, the notice was sent and delivered after midnight on 1 April 2021, so it was time-barred and invalid; the consequential reassessment action could not stand. Case-Laws Income Tax Mon, 05 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773657