Income Tax Rectification Order Quashed for Missing DIN & Limitation Breach

Siemens Limited Vs DCIT (Bombay High Court) The Bombay High Court examined the validity of a rectification order purportedly passed under Section 154 of the Income-tax Act, 1961 for Assessment Year 2005–06. The core challenge was to an order dated 29 March 2024 which did not bear a Document Identification Number (DIN) and to a subsequent intimation letter dated 10 July 2024 that sought to assign a DIN to that order. The petitioner contended that the order was invalid for non-compliance with CBDT Circular No. 19/2019, which mandates that every notice, order, or communication issued by the Inc...