Case Law Details
PCIT Vs Tata Medical Centre Trust (Calcutta High Court)
Calcutta High Court: Invalid Order Without Mentioning DIN – In a recent decision, the Calcutta High Court addressed the validity of an income tax order passed without mentioning the Document Identification Number (DIN). Here’s a summary of the case:
Background: The case revolved around an order issued under Section 263 of the Income Tax Act. The issue at hand was whether the absence of the DIN in the order rendered it invalid, despite subsequent communication.
The Tribunal’s Findings: Upon examination, the Income Tax Appellate Tribunal found that the order did not include the DIN, which was required by Circular No. 19/2019 issued by the Central Board of Direct Taxes (CBDT). This circular stipulated that any communication not in conformity with its requirements would be considered invalid.
The Tribunal’s Rationale: The Tribunal emphasized that the Circular explicitly mandated the inclusion of the Document Identification Number in the body of the communication. The absence of this essential detail in the order under Section 263 raised questions about its compliance with the Circular.
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