The Assessing Officer issued notice under section 148 of the Act on the basis of alleged unaccounted cash receipts. The assessee challenged the very foundation of the reassessment proceedings, arguing that the mandatory sanction under section 151 of the Act  as required before issuance of notice under section 148  was neither manually signed nor digitally signed by the competent authority. The sanction sheet merely contained the name and designation of the Principal Commissioner of Income-tax (PCIT), without any signature, initials, or DSC.The assessee  heavily on the Allahabad High Court decision in Vikas Gupta v. UOI (2022) 448 ITR 1 (All)(HC), which held that unsigned approvals do not fulfil the mandatory requirement of “authentication” under section 282A(1). The issue before the Tribunal was  whether reassessment proceedings initiated under section 147/148 are valid when the mandatory approval under section 151 is unsigned — i.e., neither manually nor digitally signed ,and whether such approval satisfies the legal test of authentication under section 282A of the Income-tax Act.
The Tribunal, after extensively examining the provisions of sections 151 and 282A, held that , the Authentication under section 282A(1) is not a mere procedural formality,  it is a statutory mandate.An unsigned approval cannot be considered valid, whether issued in paper form or electronic form. A notice or document must bear a valid manual or digital signature to be held as “signed”.The approval obtained in the case was admittedly not signed by the PCIT, either physically or electronically. The Tribunal distinguished the contrary view expressed by the Chhattisgarh High Court in Bharat Krishi Kendra v. UOI (2022) 444 ITR 584, noting that it was a single-judge decision and did not deal with section 282A(1) in detail.The Tribunal followed the ratio of Vikas Gupta (All)(  HC) and Daujee Abhushan Bhandar v. UOI (2022) (All)(HC), as both were Division Bench rulings specifically interpreting section 282A(1). The Tribunal further relied on the Supreme Court decision in CIT v. Vegetable Products Ltd. (1973) 88 ITR 192 (SC), which laid down that where two views are possible on a provision, the view favourable to the assessee must be adopted.

Accordingly, the Tribunal held that the unsigned sanction was invalid, and since valid prior approval is a jurisdictional condition under section 151, the entire reassessment proceedings were bad in law therefore
 reassessment proceedings initiated on the basis of such approval are without jurisdiction and hence quashed. (ITA Nos. 4147 to 4153 & 4585 to 4593/Mum/2024,  dt  03-07 -2025 )  ( AY. 2016–17 )