The Hon’ble Tribunal held that the assessment orders and the penalty orders were invalid and non-est in the eye of law, as they did not comply with the mandatory requirements of the CBDT Circular No. 19/2019. The bench relied on the decision of the Delhi High Court in CIT (International Taxation) v. Brandix Mauritius Holdings Ltd., which held that any communication issued by the revenue without DIN, except in the circumstances specified in the CBDT Circular, would be treated as non-est in law and would not confer any jurisdiction on the revenue to make any assessment or levy any penalty. The bench also observed that the revenue had not shown any exceptional circumstances or approval for issuing the orders manually without DIN, as required by the CBDT Circular. The bench quashed the assessment orders and the penalty orders and allowed the appeals of the assessee.  (AY. 2007-08, 08-09, 09-10, 12-13,  2013-14.)