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2023 (12) TMI 928 - AT - Income TaxIssuance of assessment order without DIN - violation of CBDT Circular No.19/2019 requiring mandatory DIN - scope of subsequent issue of DIN - HELD THAT:- Issuance of assessment order without DIN as it is a matter of record that the impugned assessment order neither contain any DIN and nor any reason for non-mentioning of DIN thereof. Rather, we are in complete agreement with the above contentions of the assessee. In our view, the subsequent communication issued by the Ld. AO generating DIN for the impugned assessment order cannot make good the deficiency in the assessment order issued without generating DIN. In taking this view we are supported by the ratio decidendi of the decision of Hon’ble Delhi High Court in CIT (International Taxation) vs. Brandix Mauritius Holdings [2023 (4) TMI 579 - DELHI HIGH COURT] - Thus we are inclined to quash the assessment order passed by the Ld. AO under section 153C/143(3) of the Act. Decided in favour of assessee.
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