The additional grounds relate to the validity of Order under Section 263 for the reason that the Order issued was a manual order and did not contain document identification number (DIN) which was not in accordance with the instruction of CBDT issued vide Circular No. 19 of 2019 dated 14th August, 2019 [2019] 416 ITR (St.) 140.

Held that according to Circular No. 19 of 2019 dated 14th August, 2019 all communication must have a computer-generated identification number. However, in exceptional circumstances, manual issuance was allowed, but in such cases, it must be explicitly mentioned that the communication was issued manually without a document identification code and must have written approval of the Chief Commissioner or Director General of Income-tax. Failure to comply with these mandatory requirements rendered the communication invalid and deemed never to have been issued. Therefore, the order was not in conformity with CBDT Circular, hence, the orders passed under Section 263 for assessment years 2014-15 to 2016-17 were invalid and deemed to have never been issued. Followed Tata Medical Centre Trust v. CIT(E) [2023] 33 ITR (Trib.)-OL-495 (Kol.) and Brandix Mauritius Holdings Pvt. Ltd. v. Dy. CIT (IT) (AY. 2014 -15  to 2016 -17)