Income tax assessment orders challenged over missing DIN and signature; deemed authentication upheld, profit estimate confirmed, appeals dismissed.

The dominant issue was whether assessments were void for want of DIN or authentication. For one year, the Tribunal held the assessment complied with CBDT Circular 19/2019 because a contemporaneous intimation/communication bearing DIN, along with demand notice, evidenced electronic issuance and portal upload on the assessment date; hence the DIN objection failed and the appeal was dismissed. For another year, it held that, under s. 282A(2) and r. 127A, printing the AO's name/designation and electronic transmission/website display constitutes deemed authentication; absence of a separate physical/digital signature did not vitiate the order, so the appeal was dismissed. On estimation of profit rate for a later year, returned income accepted under s. 143(3) and lack of turnover proof foreclosed reduction; assessed income was confirmed and the appeal dismissed.

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Issues Involved:
1. Validity of assessments without Document Identification Number (DIN).
2. Validity of assessments without physical or digital signatures.
3. Adoption of net profit rate for different assessment years.

Summary:

1. Validity of assessments without Document Identification Number (DIN):
The assessee contended that the assessment order was invalid due to the absence of a Document Identification Number (DIN). However, the Tribunal found that the assessment order dated 30.11.2021 did bear a DIN, as evidenced by a communication dated the same day. The Tribunal noted that the assessment order and the intimation were uploaded on the Revenue's portal on 30.11.2021, in compliance with Board Circular 19/2019. The Tribunal dismissed the assessee's appeal for AY 2015-16, stating that the objection was invalid and unfortunate.

2. Validity of assessments without physical or digital signatures:
For AY 2016-17 and 2019-20, the assessee argued that the assessment orders were not signed, either physically or digitally. The Tribunal examined the assessment records and found a physically signed copy of the assessment order for AY 2016-17. The Revenue explained that due to technical problems, digital signatures might not work, and in such cases, orders are manually signed. The Tribunal upheld the validity of the assessment order, stating that there was due compliance with s. 282A r/w r. 127A of the Income Tax Rules, 1962. For AY 2019-20, the Tribunal found that the assessment order bore the name and designation of the Assessing Officer, fulfilling the condition of s. 282A when read with r. 127A. The Tribunal dismissed the assessee's appeal for AY 2016-17 and 2019-20, finding no merit in the objections.

3. Adoption of net profit rate for different assessment years:
The assessee initially returned income under section 44AD of the Act, which was not accepted due to the non-resident status. The Assessing Officer (AO) applied a net profit rate of 3% for AY 2015-16, which the Commissioner of Income Tax (Appeals) [CIT(A)] reduced to 2%. For AY 2019-20, the AO applied a profit rate of 5%, which was confirmed by the CIT(A). The Tribunal found that the assessee admitted to suppressing sales and not maintaining books of account. The Tribunal noted that the assessee's brother-in-law, managing the business, admitted to sales suppression and a profit rate of 5% during the survey. The Tribunal upheld the AO's adoption of a higher net profit rate of 5% for AY 2019-20, finding it consistent with the estimated turnover and profit rate. The Tribunal dismissed the assessee's appeals, confirming the assessed income.

Conclusion:
The Tribunal dismissed the assessee's appeals for AY 2015-16, 2016-17, and 2019-20, finding no merit in the objections raised regarding the validity of assessments and the adoption of net profit rates. The Tribunal confirmed the assessed income as determined by the AO and CIT(A).

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