Assessment orders without computer-generated DIN after October 2019 are invalid and deemed never issued

The ITAT Delhi held that assessment orders issued without mentioning computer-generated DIN after October 1, 2019 are invalid and deemed never issued. The AO failed to provide reasons for omitting DIN or mention approval from competent authority as required by the circular. Following the circular's clear mandate and judicial precedents including Brandix Mauritius Holdings Ltd, the tribunal declared the assessment orders as non-est, treating them as if they were never issued due to non-compliance with mandatory DIN requirements.

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Issues Involved:
The judgment deals with the validity of assessment orders due to the absence of Document Identification Number (DIN) as mandated by CBDT Circular No.19/2019 and the legality of assessment framed under section 153A without incriminating material.

Issue 1: Validity of Assessment Orders without DIN:
The assessee contended that the assessment orders were invalid as they were issued without mentioning the DIN, citing CBDT Circular No.19/2019. The Circular mandated that no communication should be issued without a DIN after October 1, 2019. The Assessing Officer's report acknowledged that DINs were generated but manual orders were uploaded due to ITBA Portal limitations. The Tribunal noted that the Circular had statutory effect and any communication not conforming to it would be deemed invalid. As the assessment orders lacked DIN and reasons for the absence, they were declared non-est and set aside based on precedents and the Circular's provisions.

Issue 2: Legality of Assessment under section 153A:
The second issue raised pertained to the legality of the assessment framed under section 153A without any incriminating material found during the search. The Tribunal, however, did not delve into this issue as the assessment orders were quashed due to the absence of DIN, rendering the issues in Revenue's appeal on merits academic. Consequently, the Revenue's appeals were dismissed, and the assessee's cross-objections were allowed, leading to the setting aside of the orders of the first appellant authority.

Separate Judgment:
No separate judgment was delivered by the judges in this case.

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