DIN compliance for assessment orders: failure to follow mandatory manual-issue conditions invalidates the communication and related demand notices.

A manual assessment communication issued after 1 October 2019 must comply with the DIN regime and the exception procedure in Circular No. 19 of 2019. Where a document is issued without a computer-generated DIN, the authority must record reasons, obtain prior written approval, note the date of approval, and use the prescribed endorsement format; failure to show strict compliance with these mandatory conditions renders the communication invalid. On the facts, the assessment order and consequential demand notices were quashed, and the matter was remitted for fresh assessment after further submissions and a personal hearing.

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Issues: Whether the assessment order, issued without a Document Identification Number and without strict compliance with Circular No. 19 of 2019, was valid.

Analysis: The assessment order was challenged on the ground that communications issued after 1 October 2019 were required to bear a computer-generated DIN, and that any manual issuance had to satisfy the conditions prescribed in the circular, including recording reasons, prior written approval, the date of approval, and use of the prescribed endorsement format. The order and the supporting material did not satisfactorily show compliance with those mandatory requirements. In the absence of DIN and proof of adherence to the exception procedure, the order could not be sustained.

Conclusion: The assessment order and consequential demand notices were quashed and set aside.

Final Conclusion: The matter was sent back for fresh assessment after providing the assessee an to make further submissions and after affording a personal hearing.

Ratio Decidendi: Where a circular prescribes mandatory conditions for issuance of a manual assessment communication in the absence of DIN, non-compliance with those conditions renders the communication invalid.

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