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2022 (11) TMI 1379 - AT - Income TaxValidity of revision order passed by CIT w/o mentioning DIN - no Document Identification Number (DIN) has been mentioned in the body of the impugned order which was in violation of Circular No.19 of 2019 of CBDT - HELD THAT:- The Coordinate Bench of the Kolkata Tribunal in the case of “Smt. Sunita Agarwal vs. ITO” [2022 (11) TMI 1348 - ITAT KOLKATA] taking note of the directions/observations made in the case of “Pradeep Goyel vs. UOI” [2022 (8) TMI 216 - SUPREME COURT] has quashed the order of PCIT issued without on the ground of non-mentioning of DIN in the said order. So far as the contention of the Ld. DR that the DIN has been duly mentioned in the intimation letter for order u/s 263 of the even date, is concerned, we note that as per para 2 of the CBDT Circular No.19/2019, the DIN should be duly quoted in the body of such communication or order. Therefore, the mentioning of DIN on intimation letter does not validate the order issued without DIN being mentioned in the body of the order, and hence the same is liable to be treated as non-est. Thus in the light of the decisions of “Tata Medical Centre Trust” [2022 (7) TMI 1334 - ITAT KOLKATA] and “Smt. Sunita Agarwal vs. ITO” [2022 (11) TMI 1348 - ITAT KOLKATA] the impugned order of ld. CIT(Exemption) is, hereby, quashed.
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