Pratap Singh Yadav. v. DCIT (2024) 204 ITD 511 (Delhi) (Trib.)

S. 153C : Assessment-Income of any other person-Search-Additional ground-Document Identification Number-Un explained money-Assessment order neither contained any Document Identification Number nor any reason for non mentioning thereof, assessment order-Violation of Circular No. 19/2019, dated 14-8-2019-Order is quashed. [S. 69A, 143(3)]

Assessing Officer passed assessment order under section 153C read with section 143(3) on assessee and made addition to his income treating certain amount as unexplained money under section 69A. Addition was affirmed by the CIT(A). On appeal the assessee raised additional ground that the Assessment order neither contained any Document Identification Number nor any reason for non mentioning thereof, assessment order is bad in law. Tribunal held that since assessment order neither contained any Document Identification Number (DIN) nor any reason for non mentioning thereof and subsequent communication issued by Assessing Officer generating DIN for assessment order could not make good deficiency in assessment order issued without generating DIN, assessment order in question was in violation of Circular No. 19/2019, dated 14-8-2019  quashed. (AY. 2015-16)

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