DIN compliance in tax communications is mandatory; later intimation cannot cure an order invalid at issuance.

Income-tax communications issued after 01.10.2019 without a computer-generated DIN, and without recording the prescribed reasons, prior approval and related particulars in the body of the order, were held to be contrary to CBDT Circular No. 19/2019 and non-est in law. The Tribunal further held that later intimation of the DIN did not cure the defect, because validity must exist at the time of issuance. The additional legal ground was admitted as it arose from the record and needed no further factual enquiry, and the impugned orders were treated as never having been issued.

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Issues: Whether an assessment order or appellate order issued without quoting a computer-generated Document Identification Number and without recording the prescribed reasons and approval in the body of the communication is invalid, and whether subsequent intimation of the DIN cures the defect.

Analysis: The Tribunal admitted the additional legal ground as it arose from the impugned orders and required no further factual enquiry. It held that CBDT Circular No. 19/2019, issued under section 119 of the Income-tax Act, 1961, mandated quotation of DIN in communications issued on or after 01.10.2019, and that the exceptional cases permitting manual issuance required recording of reasons, prior approval of the specified higher authority, and mention of those particulars in the communication itself. A DIN-less order not complying with those conditions was treated as contrary to the circular and non-est in law. The Tribunal further held that later intimation of the DIN within the stipulated period did not cure a communication that was invalid at the time of issuance.

Conclusion: The impugned orders issued without complying with the DIN mandate were invalid and deemed never to have been issued; the additional ground was allowed in favour of the assessees.

Ratio Decidendi: A communication issued by the income-tax authorities after 01.10.2019 without quoting DIN, and without satisfying the prescribed exceptional-condition requirements in the body of the communication, is invalid and cannot be regularised merely by later intimation of the DIN.

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