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2024 (1) TMI 544 - AT - Income TaxValidity of CIT’s impugned revision order quoting no “DIN” number - as CIT’s impugned order duly stood allotted the corresponding DIN number - HELD THAT:- CBDT’s Circular No.19 of 2019 dated 14.08.2019 issued under section 119 of the Act has made it clear that such a failure renders the same as void. Not a curable defect u/s 292B. As decided in Ashok Commercial Enterprises Vs. ACIT [2023 (9) TMI 335 - BOMBAY HIGH COURT] order issued without a DIN does not bear the required format set out in paragraph 3 of the Circular and, therefore, the assessment orders without quoting DIN ought to be treated as invalid and deemed never to have been issued - The consequences of contravention of the Circular set out above, therefore, ought to be given full effect to. The object of the said Circular is clear and laudatory and intended to ensure that proper trail of all assessment and other orders are maintained and further that any deviation therefrom can only be undertaken after prior written approval of the higher authorities under the Act. Delay of 581 days in filing of the instant appeal against PCIT’s revision order is condoned since falling under Covid-2019 pandemic outbreak period between 15.03.2020 to 28.02.2022 as per hon'ble apex court’s directions in Cognizance for Extension of Limitation, In re [2021 (11) TMI 387 - SC ORDER] read with judgment in Cognizance for Extension of Limitation, In re [2021 (3) TMI 497 - SC ORDER] and [2020 (5) TMI 418 - SC ORDER] excluding the covid-19 pandemic outbreak period from for all intents and purposes under the limitation law.
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