Central Board of Direct Taxes vide Circular No. 19/2019, mandated that no communications related to notice, order, appeal, assessment, investigation or any other correspondence shall be issued by the Income Tax Department without a computer-generated Document Identification Number (DIN). The Circular further provides that any communication issued without DIN shall be rendered as invalid and shall be deemed to have never been issued.
Our Partner, Mr. Parveen Kumar and Senior Tax Manager, Ms. Sofiya Syed delves into the fundamental aspects surrounding the implementation of Document Identification Number (DIN) mandated vide CBDT, vide Circular No. 19/2019. They underscore the exceptional circumstances laid down in the Circular where communication can be issued by the Department without quoting DIN, touch upon the procedure to be followed for issuing communication without DIN in such exceptional circumstances, and regularisation requirements for the same. They discuss the possible implications in different situations, within the context of various legal precedents where: (i) no DIN was generated/quoted at all, (ii) DIN generated and quoted in separate intimations, (iii) DIN not quoted in notice u/s 148/143(2), etc. and (iv) the notice without DIN is not challenged in assessment proceedings but at a later stage.
This article was first published on Taxsutra (a trusted online source of tax) on August 7th, 2023.
The summary information herein has been compiled by our expert team of tax consultants based on CBDT Notification No. 19/2019 dated August 14, 2019, regarding DIN and the interpretation of recent judicial precedents related thereto. While the information is believed to be accurate, we make no representations or warranties, express or implied, as to the accuracy or completeness of it. Readers should conduct and rely upon their own examination and analysis and are advised to seek their own professional advice. This note is not an offer, advice, or solicitation. We accept no responsibility for any errors it may contain, whether caused by negligence or otherwise, or for any loss, howsoever caused or sustained, by the person who relies upon it.