The Dispute Resolution Panel issued its directions without quoting a valid computer-generated Document Identification Number (DIN) as mandated by CBDT Circular No. 19 of 2019. The Tribunal held that compliance with the Circular was mandatory and the subsequent communication assigning a handwritten DIN could not cure the defect. As the directions were issued without a valid DIN, they were deemed never to have been issued and were liable to be quashed as null and void ab initio. The merits of the transfer pricing adjustment were left open. (AY. 2017-18).