Signed statutory approval is essential for reassessment jurisdiction; electronic authentication cannot replace a manual or digital signature.
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....Signed approval by the prescribed authority is a jurisdictional precondition to issuing a reassessment notice and safeguards against arbitrary reopening. The approving authority must record satisfaction, after considering the recorded reasons and supporting material, through a manual or digital signature. A DIN, electronic transmission, or printed officer name and designation may establish authenticity but cannot replace the required signature. A curative provision introduced after the relevant approval cannot validate the defect. An unsigned approval therefore cannot confer reassessment jurisdiction, rendering consequential reassessment action unsustainable.....
TaxTMI