The assessment order bore only a manually written DIN, while the computer-generated DIN was issued nearly three weeks later. The Tribunal held that CBDT Circular No. 19/2019 mandates that every communication must bear a computer-generated DIN at the time of issuance. Subsequent generations of DIN cannot cure the defect. Accordingly, the reassessment proceedings were held to be void ab initio. (AY. 2014-15 to 2017-18, 2019-20 to 2022-23)
Estate Investment Company (P.) Ltd. v. DCIT (2025) 238 TTJ 585 (Mum)(Trib).
S. 147:Reassessment-Manually written DIN-Subsequent generation of DIN-Assessment void-CBDT Circular No. 19/2019. [S. 119, 143(3) 148]
Leave a Reply