आयकर अपीलीय अिधकरण, ‘ए’ (cid:1)यायपीठ, चे(cid:9)ई।

IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI (cid:1)ी एबी टी. वक(cid:10), (cid:11)ाियक सद(cid:17) एव ं

(cid:1)ी एस. आर. रघुनाथा, लेखा सद(cid:9) के सम(cid:27)

BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.2236/Chny/2024 िनधा(cid:14)रण वष(cid:14)/Assessment Year: 2014-15 Doulat Jain, v. The DCIT, 55, Narayana Mudali Street, Corporate Circle-2(1), Sowcarpet, Chennai.

Chennai-600 079.

[PAN: AACPJ 0922 A (अपीलाथ(cid:22)/Appellant) ((cid:23)(cid:24)यथ(cid:22)/Respondent)

अपीलाथ(cid:22) क(cid:26) ओर स/े Appellant by : Mr.N. Arjun Raj, Advocate (cid:23)(cid:24)यथ(cid:22) क(cid:26) ओर स े /Respondent by : Mr.R. Raghupathy, Addl.CIT सुनवाईक(cid:26)तारीख/Date of Hearing : 12.08.2025 घोषणाक(cid:26)तारीख /Date of Pronouncement : 07.10.2025 आदशे / O R D E R PER ABY T. VARKEY, JM This is an appeal preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals)/NFAC, (hereinafter referred to as “the Ld.CIT(A)”), Delhi, dated 26.06.2024 for the Assessment Year (hereinafter referred to as "AY”) 2014-15.

2. At the outset, the Ld.AR of the assessee drew our attention to additional grounds filed by the assessee and especially Ground No.5, which is a legal issue alleging that the assessment order passed by the AO u/s.147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘) is bad in law, since no ‘DIN’ has been quoted in the body of the assessment order. Ground No.5 reads as under:

05. The NFAC, Delhi failed to appreciate that in the absence of incorporation of Document Identification Number in the body of the re- assessment order passed under Section 147 of the Act as mandated by Circular No. 19/2019 dated 14.08.2019, the consequential re- assessment order passed should be reckoned as bad in law / non erst in law.

3. By raising the aforesaid legal issue, as noted, the assessee is assailing the order of the AO dated 24.10.2019 passed u/s.143(3) r.w.s.147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘) as invalid being per se violative of CBDT Circular No.19/2019 dated 14.08.2019, which sets out the manner in which Document Identification Number [in short “DIN"] is required to be generated while communicating a notice, order, summon, letter and a correspondence issued by the Income-tax Department. It is noted that there is a specific requirement under the 2019 Circular to quote the DIN in the body of any such communication. And in the absence of the same i.e. if “DIN” is not quoted in the body of the impugned assessment order dated 24.10.2019, according to the Ld.AR, the assessment order is invalid in the eyes of law.

For examining the same, it would be gainful to reproduce CBDT Circular No.19/2019 dated 14.08.2019, which reads as under:

With the launch of various e-governance initiatives, Income-tax Department is moving toward total computerization of its work. This has led to a significant improvement in delivery of services and has also brought greater transparency in the functioning of the tax- administration. Presently, almost all notices and orders are being generated electronically on the Income Tax Business Application (ITBA) platform. However, it has been brought to the notice of the Central Board of Direct Taxes (the Board) that there have been some instances in which the notice, order, summons, letter and any correspondence (hereinafter referred to as "communication") were found to have been issued manually, without maintaining a proper audit trail of such communication.

2. In order to prevent such instances and to maintain proper audit trail of all communication, the Board in exercise of power under section 119 of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), has decided that no communication shall be issued by any income-tax authority relating to assessment, appeals, orders, statutory or otherwise, exemptions, enquiry, investigation, verificati