https://www.taxtmi.com/caselaws?id=795012 A reassessment notice digitally signed before 1 April 2021 but transmitted through the Department's ITBA system on or after that date is described as issued on the transmission date, rather than its generation or signature date. Where transmission occurred on 1 April 2021, the substituted reassessment framework applies. The notice is to be treated as a show-cause notice under Section 148A(b), requiring disclosure of relied-upon material, consideration of objections, and an order under Section 148A(d) before further action. Assessments completed without that procedure are described as unsustainable, while statutory defences and legal contentions remain open. en-us Mon, 06 Jul 2026 00:00:00 +0530 Wed, 15 Jul 2026 08:21:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795012 A reassessment notice digitally signed before 1 April 2021 but transmitted through the Department's ITBA system on or after that date is described as issued on the transmission date, rather than its generation or signature date. Where transmission occurred on 1 April 2021, the substituted reassessment framework applies. The notice is to be treated as a show-cause notice under Section 148A(b), requiring disclosure of relied-upon material, consideration of objections, and an order under Section 148A(d) before further action. Assessments completed without that procedure are described as unsustainable, while statutory defences and legal contentions remain open. Case-Laws Income Tax Mon, 06 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795012