Subsequent generation of DIN would not change illegality of order: ITAT Indore

Shri Ishak Vs ITO (ITAT Indore)

The case of Shri Ishak Vs ITO (ITAT Indore) revolves around the subsequent generation of a Document Identification Number (DIN) in an order passed under section 154 of the Income Tax Act. It raises important questions about the validity of such an order when the DIN was not initially provided. In this article, we delve into the facts of the case, the arguments presented by both parties, the observations made by the Hon. ITAT, and the ultimate conclusion.

Facts of the case

1. That the order u/s. 154, dated 10.10.2019 was initially issued in manual mode on 10.10.2019, without generating a Document Identification Number (DIN), in contravention of the CBDT Circular No.19 of 2019 dated 14.8.2019.

2. That in order to regularize the Manual Order u/s. 154 dated 10.10.2019, the Ld. AO generated a DIN, through the ‘Intimation Letter’ dated 14.10.2019.

Please become a Premium member. If you are already a Premium member, login here to access the full content.