Special Income Tax Audit Without Valid DIN-Based Approval Void Ab Initio: Bombay HC

Sanjay Nathalal Shah Vs ACIT (Bombay High Court) The Bombay High Court held that a special audit ordered under Section 142(2A) of the Income-tax Act, 1961 is void ab initio if the mandatory prior approval of the Principal Commissioner of Income Tax does not bear a valid Document Identification Number (DIN) as required under CBDT Circular No. 19/2019 dated 14.08.2019. The petitioner challenged the validity of the order dated 10.02.2025 directing a special audit for Assessment Year 2023–24 and the consequential special audit report dated 06.06.2025. A key contention was that the jurisdictional...