Held, that there was a clear violation of the specific requirement under the Central Board of Direct Taxes Circular No. 19 of 2019 ([2019 416 ITR (St.) 140) to quote the document identification number in the body of the assessment orders. Para 4 of the Circular which says in unequivocal terms that any communication which is not in conformity with paras 2 and 3 shall be treated as invalid and shall be deemed never to have been issued. Thus, the assessment orders passed by the Assessing Officer under section 143(3) of the Income-tax Act, 1961 read with section 153A of the Act and as a natural corollary, the orders of the Commissioner (Appeals) were non est.(AY.2013-14 to 2018-19)
Panna Lal and Co. v. Dy. CIT (2023)108 ITR 46 (SN)(Delhi)(Trib)
S. 143(3): Assessment-Document Identification Number-Failure to allot and mention in assessment order-Assessment order deemed never to have been passed —Central Board Of Direct Taxes Circular No. 19 Of 2019, Dated 14-8-2019-Order is bad in law-Additional ground is admitted-Order is quashed. [S.153A, 254(1)]