Tata Medical Centre Trust v. CIT(E) (2022) 196 ITD 302 / (2023) 222 TTJ 249 (Kol.)(Trib.)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Document Identification No. (DIN)-Revision order passed manually without Document Identification No. (DIN) in its body-Held to be invalid and deemed to have never been issued.

Held that in view of CBDT’s Circular No. 19/2019, dated 14-8-2019, revision order under section 263 issued manually without Document Identification No. (DIN) is invalid and deemed to have never been issued if written approval of Chief Commissioner/Director General of Income-tax is not obtained in prescribed format for such manually issued order.  Order passed without a DIN, order passed by Commissioner was invalid and deemed to have never been issued. (AY. 2016-17)