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 ]