ALLAHABAD HIGH COURT · SOURCE-REVIEWED PROCEDURAL ORDER
Archana Jain v. Principal Commissioner of Income Tax-1, Kanpur and Two Others
Writ Tax No.453 of 2022 ·
Supplied court order; no reported citation stated
Writ dismissed following withdrawal request after competing email and postal-dispatch submissions; no general limitation holding.
Division Bench · Surya Prakash Kesarwani · Jayant Banerji
1. Facts of the case
Archana Jain challenged a Section 148 notice dated 31 March 2021 in WritTax 453/2022. Her counsel said it was digitally signed 31 March 2021 but emailed 1 April 2021 at 06:37 AM and received at about 04:59 PM, and argued that it was outside Section 149(1) limitation. These are the petitioner's submissions.
2. Discussion by the Hon’ble Court
Revenue counsel stated on instructions that the notice had also been sent by speed post on 31 March 2021 and produced a photocopy of the postal receipt, which was retained on record. Revenue then alleged suppression of that postal dispatch. This allegation is not an express judicial finding of fraud.
3. Judicial decision
Petitioner's counsel then requested dismissal as withdrawn. The operative paragraph states that the writ petition is dismissed.
4. Outcome / in whose favour
The writ ended following the withdrawal request. The Court did not announce a general rule that digital signing, emailing, receipt or postal dispatch controls issuance for limitation purposes.
5. AKHB REVIEW POINT
Preserve the competing electronic and postal narratives as attributed submissions and identify the receipt as the document produced. Do not turn this procedural dismissal into a binding merits holding on Section 149 limitation or a concluded suppression finding. No AY/PAN is stated.
Source and verification
Complete supplied one-page original read and visually inspected; original PDF bytes verified by SHA-256. Only source-identified provisions and assessment years are recorded. No PAN is stated. Subsequent treatment and current law have not been cleared.
Source SHA-256: 694170394c8c415241df7bf57dcbec0e458ba7d1d321efac3560f50ea47ffd9a
Only source-identified provisions are recorded. No current monetary threshold, current statutory equivalence or 2025 Act applicability is inferred.
Source checked 2026-10-19. Subsequent proceedings and current precedential treatment have not been comprehensively verified.
AI disclosure and professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court’s holding. No current-law clearance is claimed.