and all these correspondences have been made
manually. Learned Senior Counsel has drawn our attention
towards the assessment order (Annexure ’15’) and the notice of
demand under Section 156 of the Act of 1961 attached therewith to
Patna High Court CWJC No.7244 of 2022 dt.25-04-2025
show that these documents have been signed by hand and not
digitally. It is submitted that in view of the scheme and the circular
referred hereinabove, these documents are to be held invalid.
11. Learned Senior Counsel has further submitted that it
would appear from the statements made in the counter affidavit
that there were three partners of the petitioner firm, namely, Smt.
Kumud Bagla, Mr. Pradeep Bagla and Mr. Rajesh Bagla. Smt.
Kumud Bagla sent a complaint on 22.02.2021 to the Department.
As per the said complaint, the petitioner had understated its actual
business receipt in order to defraud the revenue during the
financial year 2015-16 and 2016-17.