This Tax Alert summarizes a ruling of the Delhi High Court (HC), dated 27 September 2022, in a batch of cases with the lead case being Suman Jeet Agarwal[1]. The issue pertains to the determination of date of issuance of reassessment notice under electronic mode. In all the cases under dispute, notices for reassessment were generated through ITBA on 31 March 2021, but the email through which notices were sent were issued post 1 April 2021 to the taxpayers, either with or without digital signatures. Significance of determination of date of issue was that if the date of issue is held to be on or before 31 March 2021, the reassessment proceedings would be governed by unamended law and if the date of issue is on or after 01 April 2021, reassessment is to be under new reassessment regime as operative from 01 April 2021, subject to applicable limitation period.his Tax Alert summarizes a recent Delhi High Court (HC) ruling in the case of Touchstone Holdings Pvt. Ltd.[1] (Taxpayer) wherein with respect to the issue of time barring of reassessment notice and order, the HC has upheld the validity of the reassessment notice and order dated 20 July 2022 for tax year (TY) 2012-13 issued by the tax authority in accordance with the Supreme Court ruling in the case of Ashish Agrawal (SC ruling) and Central Board of Direct Taxes (CBDT ) Instruction 1/2022 (CBDT Instruction).
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