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2023 (11) TMI 186 - ITAT DELHITP order u/s 92CA without quoting the mandatory DIN - simultaneous DIN number was generated and communicated - assessee submitted that the TPO order doesn’t bear DIN in the light of Circular No.19/2019 dated 14.08.2019 - HELD THAT:- As decided in ABHIMANYU CHATURVEDI, MALLIKA CHATURVEDI, ALKA CHATURVEDI VERSUS DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-I, NOIDA [2023 (8) TMI 378 - ITAT DELHI] forwarding of the intimation of generation of the DIN in ITBA is only a subsequent action and that is not part of assessment order. The manner in which the word ‘communication’ is defined shows every notice, order, summons, letter and any correspondence from Tax authorities should have a DIN quoted and it is for this reason that the Intimation issued about the DIN of assessment order itself has a DIN quoted on it. Thus simultaneous issue of the DIN number is insignificant and superfluous exercise, in the absence of mentioning the DIN number on the body of the communication. Hence, the grounds taken up for discussion are decided in favour of the assessee.
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