On writ  allowing the petition the Court held  that the appraisal report was available before the Assessing Officer during the original assessment. The assessment order was passed based on materials seized during search and seizure operations including the ledger and cash book of different years found in the Tally data of the assessee and in the wake of the fact that the assessee had failed to produce any books of account, ledgers, bills, vouchers and any other Supporting evidence substantiating his case. From the record, it was apparent that the initiation of proceedings for reassessment was not based on discovery of new materials which were not available before the Assessing Officer during. The audit objection was based upon the same appraisal report. The notice dated March 31, 2021 and the order rejecting his objection dated February 21, 2022 were accordingly to be set aside. Court also held that in terms of the existing provisions of section 149(1)(b) prior to amendment by the Finance Act, 2021 with effect from April 1, 2021, reassessment proceedings could be initiated beyond the period of four years up to six years counted from the end of the assessment year, i.e., in the assessee’s case March 31, 2015 up to March 31, 2021. The notice dated March 31, 2021 under section 148 was not barred by limitation.  That under the provisions of section 151 of the Act as they stood before the amendment with effect from April 1, 2021, the Principal Commissioner was fully competent to accord permission for reopening of assessments beyond the period of four years as prescribed under section 149(1)(b). That the Department had made a categorical statement that the Assessing Officer issued notice under section 148 of the Act by digitally signing the notice on March 31, 2021 at 7.01 p.m. The moment he put his digital signature on the notice in the specified online portal of the Department, it went out of his hands to the centralised online application unit of the Income-tax Department and, therefore, it was beyond the control of the Assessing Officer. It was the software on the online portal, to which the Department had no access, which automatically delivered the notice at the e-mail address of the assessee. Therefore, the notice under section 148 issued on March 31, 2021 at 7.01 p.m. was within the prescribed time limit of six years as provided under section 149(1)(b) of the Act. It was only the generation of the document identification number by the online portal that had been done on April 1, 2021. The notice was not barred by limitation though it may have been uploaded on the portal on April 1, 2021.(AY. 2014-15)