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    <title>2026 (5) TMI 169 - ITAT RAJKOT</title>
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    <description>Reassessment under sections 147 and 148 requires valid sanction under section 151, and that approval must bear a manual or digital signature as a mandatory safeguard. Where the approval on record was issued electronically but carried neither a manual signature nor a digital signature certificate, the sanction was invalid and could not support reopening. The reassessment initiated on that basis therefore lacked jurisdiction and was quashed. Since the reassessment failed at the threshold, the merits of the addition were not examined and the addition was deleted in favour of the assessee.</description>
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    <pubDate>Mon, 13 Apr 2026 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=790967</link>
      <description>Reassessment under sections 147 and 148 requires valid sanction under section 151, and that approval must bear a manual or digital signature as a mandatory safeguard. Where the approval on record was issued electronically but carried neither a manual signature nor a digital signature certificate, the sanction was invalid and could not support reopening. The reassessment initiated on that basis therefore lacked jurisdiction and was quashed. Since the reassessment failed at the threshold, the merits of the addition were not examined and the addition was deleted in favour of the assessee.</description>
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      <pubDate>Mon, 13 Apr 2026 00:00:00 +0530</pubDate>
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