Assessment Order Without DIN Invalid Despite Later Intimation: ITAT Chennai

Doulat Jain Vs DCIT (ITAT Chennai)

The Income Tax Appellate Tribunal (ITAT), Chennai, examined whether an assessment order issued without quoting a Document Identification Number (DIN) in its body was valid in law. The appeal arose against an order passed by the National Faceless Appeal Centre (NFAC), Delhi, for the Assessment Year 2014–15. The assessee’s main contention was that the reassessment order issued under Section 147 of the Income Tax Act, 1961, was invalid since it did not contain a DIN, contrary to CBDT Circular No. 19/2019 dated 14 August 2019.

The CBDT Circular mandated that no communication relating to assessment, appeals, orders, or investigation be issued by any income-tax authority on or after 1 October 2019 unless a computer-generated DIN was allotted and quoted in the body of such communication. The circular allowed exceptions only in specific cases such as technical difficulties, communications issued outside office premises, delays in PAN migration, absence of PAN, or lack of system functionality. In such cases, the officer must record reasons in writing, obtain prior approval from the Chief Commissioner or Director General of Income Tax, and mention in the communication that it was issued manually with approval. Moreover, communications issued manually under these exceptions had to be regularized by generating and quoting a DIN within 15 working days (or 7 days in certain cases). The circular explicitly declared that any communication not in conformity with its provisions would be invalid and deemed never to have been issued.