Hardik Deepak Salot Vs ACIT (Bombay High Court)
The Bombay High Court considered writ petitions challenging income-tax proceedings on the ground that the statutory sanction relied upon by the Revenue was invalid. The petitioner contended that a copy of the sanction had not been furnished; in response, the Revenue produced a sanction letter dated 9 June 2023 issued by the Principal Commissioner of Income Tax (Central)-3, Mumbai. The petitioner argued that the sanction was invalid because it did not contain a Document Identification Number (DIN), as required under Circular No. 19/2019 dated 14 August 2019, and relied on a prior judgment of the Court holding that any document issued without a DIN is invalid and deemed never to have been issued.
The Revenue accepted that the cited judgment laid down this position and stated that it was unaware whether the ruling had been challenged before the Supreme Court. It sought liberty to take further steps if the judgment were to be reversed in the future. The Court observed that, in the present case, the sanction lacked a DIN and was therefore invalid. Consequently, the impugned order dated 9 June 2023, read with the order dated 8 December 2023, was quashed and set aside.
