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2023 (11) TMI 124 - AT - Income TaxValidity of assessment order without DIN - Communications emanating from the revenue - scope of CBDT Circular no. 19/2019 dated 14.08.2019 - HELD THAT:- A perusal of the AO order shows that it is clear in the body of AO order, no DIN number is mentioned nor there is any reason of not mentioning the DIN number in order of the AO. Is such a situation, the AO order will lose its validity. Subsequent separate communication of DIN is a superfluous exercise. Failure to Non allocate DIN is not mere mistake as corrected by taking recourse to Section 292B of the Income Tax Act We are referring to the decision of the Hon’ble jurisdictional High Court in the case of CIT vs Brandix Mauritius Holdings Ltd. [2023 (4) TMI 579 - DELHI HIGH COURT] as held that communication relating to assessments, appeals, orders, etcetera which find mention in paragraph 2 of the 2019 Circular, albeit without DIN, can have no standing in law, having regard to the provisions of paragraph 4 of the 2019 Circular. Appeal of assessee allowed.
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