Rhone Associates P. Ltd. v.ACIT (2023)108 ITR 16 (SN)/(2024) 204 ITD 136 (Delhi) (Trib)

S. 143(3): Assessment-Document Identification Number-Circular making generation and quoting of mandatory —Assessment order invalid and deemed to have never been passed.[S.119]

Held that  in the body of Assessing Officer’s order, no document identification number was mentioned nor were any reasons for not mentioning the document identification number stated. Is such a situation, the Assessing Officer’s order would lose its validity. Subsequent separate communication of document identification number was a superfluous exercise. In terms of paragraph 4 of Circular No. 19 of 2019, dated August 14, 2019, the assessment order was invalid and shall be deemed to have never been passed. Central Board of Direct Taxes Circular No. 19 of 2019, dated August 14, 2019 ([2019 416 ITR (St.) 140)(AY.2012-13)