Authentication vs. Signature: Does a DSC-enabled Portal Upload Satisfy Notice Signing Requirements?

This ruling is a critical reminder that GST adjudication and recovery documents must visibly bear a digital signature, E-sign, or Board-approved verification — backend system authentication alone will not suffice before courts. Taxpayers whose accounts have been attached or against whom recovery has been initiated on the basis of unsigned orders should immediately verify whether their SCNs and OIOs carry proper authentication and, if not, may challenge such proceedings as jurisdictionally void.