The assessee challenged the notice received by the assessee is time barred  on the ground that though the notice was digitally signed on 31^st  March 2021, the said notice was received through e-mail on April 6, 2021. Allowing the petition the Court observed that sub-section (1) of section 149 of the Income-tax Act, 1961, starts with a prohibitory words that “no notice under section 148 shall be issued for the relevant AY after expiry of the period as provided in sub-clauses (a), (b) and (c)”, section 282 of the Act provides for mode of service of notices. Section 282A provides for authentication of notices and other documents by signing it. Sub-section (1) of section 282A uses the word “signed” and “issued in paper form” or “communicated in electronic form by that authority in accordance with such procedure as may be prescribed”. Thus, signing of notice and issuance or communication thereof have been recognised as different acts. The issuance of notice and other documents would take place when the e-mail is issued from the designated e-mail address of the concerned Income-tax authority. Therefore after a notice is digitally signed and when it is entered by the Income-tax authority in the computer resource outside his control, i. e., the control of the originator then that point of time would be the time of issuance of notice. Thus, considering the provisions of sections 282 and 282A of the Act, 1961 and the provisions of section 13 of the Information Technology Act, 2000 and the meaning of the word “issue” firstly the notice shall be signed by the assessing authority and then it has to be issued either in paper form or be communicated in electronic form by delivering or transmitting the copy thereof to the person therein named by the modes provided in section 282 which includes transmitting in the form of electronic record. Section 13(1) of the 2000 Act provides that unless otherwise agreed, the dispatch of an electronic record occurs when it enters into computer resources outside the control of the originator. Thus, the point of time when a digitally signed notice in the form of electronic record is entered in computer resources outside the control of the originator, i. e., the assessing authority that shall be the date and time of issuance of notice under section 148 read with section 149.Accordingly the Court held that the notice under section 148 of the Act for the AY 2013-14 was digitally signed by the assessing authority on March 31, 2021. It was sent to the assessee through e-mail and the e-mail was undisputedly received by the assessee on its registered e-mail id on April 6, 2021. The limitation for issuing notice under section 148 read with section 149 of the Act, 1961 was up to March 31, 2021 for the AY 2013-14. Since, the notice under section 148 of the Act, 1961 was issued to the assessee on April 6, 2021 the notice under section 148 of the Act, 1961 was time barred. (AY.  2013-14)