The approval was granted in a mechanical manner and without application of mind. Reassessment notice and order is quashed. As per CBDT Circular No. 19/2019, dated 14-08-2019, it is a mandatory requirement that the Document Identification Number (DIN) must be quoted on the body of the assessment order and demand notice at the time of issuance. A subsequent generation of DIN (either on the same day or the next day) and its intimation to the assessee via a separate communication does not satisfy the conditions laid down in paragraphs 3 and 4 of the circular. Since the requirement of quoting the DIN on the original assessment order and demand notice was not met, they are unsustainable in law. (AY. 2013-14, 2014-15)
Mohd. Shafiq Cement Store v. ITO [2025] 210 ITD 1 (Amritsar)(Trib.)
S. 151 : Reassessment-Sanction for issue of notice-Approval is granted in mechanical manner-Reassessment is quashed Communication of assessment order-Assessment orders and demand notices issued u/s. 156, without a Document Identification Number (DIN) are unsustainable in law and can be considered invalid. [S. 119, 147 148, 156]
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