On writ against the issue of reassessment notice under S. 148, the Court held that the circular No 7 of 2018 dt 20 th December, 2018    acknowledged and took note of the grievances which were raised with respect to the non-functionality of the facility for digital submission of forms leading to a delayed e-filing Form 10. The CBDT also appears to have taken a sympathetic view bearing in mind the fact that the requirement of digital filing had come to introduced and become applicable for the first time in asst. yr. 2016-17. was in that backdrop that the CBDT had hoped that assessing authorities would approach the issue bearing in mind reasonable cause being established by individual assessees in case of a delayed digital submission of Form 10. The respondents allude to 3687 digital submissions of Form 10 in the month of October, 2016. The Court has not been provided any further details with respect to how that number would be representative or proof of a broad or universal functionality of the filing portal when compared with the body of assesse seeking to accumulate income under S. 11(2) the said year saw an exponential increase in the number of tax filings and with the tot number being pegged at 28.2 million. The number of 3687 thus clearly fails to inspire any confidence.  Accordingly the Court held that the action for reassess is not founded on income liable to tax having escaped assessment-Notice and order disposing the objection is quashed. (AY.  2016-17)