16. The factum of issuance of a notice under Section 148 of the 1961
Act is sufficient to attract the jurisdiction, though the requirement of
Section 148 to make reassessment is to serve the notice, for which no
limitation has been provided, as has been reiterated in the case of
Mayawati (supra).
17. Independent of the above, I also find that both, the learned
advocates for the petitioners as also for the respondents have placed
much reliance on the method of authentication of an order issued
under the said Act. In this context, I note that the method of
authentication is provided in Rule 26 of the said Rules which provides
that all applications, including reply, if any, to the notices, returns
including the details of outward and inward supplies, appeals or any
other document required to be submitted under the provisions of these
rules shall be so submitted electronically with digital signature
certificate or through e-signature as specified under the provisions of
the Information Technology Act, 2000 (Act 21 of 2000), or verified by
any other mode of signature or verification as notified by the Board in
WPA 8929 of 2025
this behalf, and sub-rule (3) of the said Rule provides that all notices,
certificates and orders under the provisions of this Chapter shall be
issued electronically by the proper officer or any other officer
authorised to issue such notices or certificates or orders, through
digital signature certificate or through e-signature as specified under
the provisions of the Information Technology Act, 2000, or verified by
any other mode of signature or verification as notified by the Board in
this behalf.
