Case Law Details
Finesse International Design Pvt. Ltd. Vs DCIT (ITAT Delhi)
Explore the landmark ITAT Delhi ruling in Finesse Intl. Design Pvt. Ltd. vs. DCIT. CBDT Circular violation deems assessment order invalid. Know more!
Introduction: In a recent case before the Income Tax Appellate Tribunal (ITAT), Delhi Bench ‘B’, the appeal filed by Finesse International Design Pvt. Ltd. against the first appellate order was heard. The case, bearing ITA No. 1298/Del/2021, pertained to the assessment year 2017-18. The appeal primarily challenged the addition/disallowance related to cash deposits in the bank account, disallowances in business promotion expenses, and the initiation of penalty proceedings under Section 270A(2) of the Income Tax Act, 1961.
Background: The appeal was centered on the assessment order dated 19.02.2021, passed by the Assessing Officer (AO) under Section 153A r.w.s 143(3) of the Income Tax Act. The appellant raised objections related to the cash deposit, business promotion expenses, and penalty proceedings. Additionally, the appellant submitted applications for the admission of additional grounds challenging the validity of the assessment order.
Additional Grounds Raised: The appellant contended that the assessment order was invalid due to non-compliance with the provisions of CBDT Circular No.19/2019, which mandates the quoting of Document Identification Number (DIN) on all communications. The appellant argued that the approval granted by the Additional Commissioner of Income Tax (Addl. CIT) under Section 153D lacked the mandatory DIN and demand order issued under section 156 were without DIN, therefore making the entire assessment process non-est and invalid.
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