ITO Vs Sai Kumar Mateti (Supreme Court of India)
The Supreme Court disposed of a batch of 103 civil appeals concerning reassessment notices by remitting the matters to the respective jurisdictional High Courts for fresh determination. The Court noted that these cases had earlier been segregated because they might relate to Assessment Year (AY) 2015-16. During the hearing, the Revenue fairly conceded that reassessment notices relating to AY 2015-16 would be barred by limitation in view of the Supreme Court’s decision in Union of India v. Rajeev Bansal. The Court observed that if the cases were found to pertain to AY 2015-16, the reassessment notices would have to be declared time-barred without any further adjudication. However, if the matters related to any assessment year other than AY 2015-16, the assessees would be entitled to raise all contentions permitted under the Supreme Court’s earlier order dated April 10, 2026, and the High Courts would decide those issues accordingly. The impugned High Court judgments were set aside, and the matters were remitted for fresh determination on these terms.
In the underlying Telangana High Court case, the assessee had challenged a notice dated March 31, 2021 issued under Section 148 of the Income Tax Act for reassessment for AY 2013-14. The challenge was based on the ground that the notice did not bear either a manual or digital signature of the issuing authority. The Department contended that the notice had been duly served, the assessee had participated in the proceedings, and a subsequent notice under Section 151 had been digitally signed. It argued that the absence of a digital signature on the Section 148 notice did not render it invalid.
