Document Identification Number compliance invalidates sanction relied on by Revenue, leaving the impugned order unsustainable.

A sanction relied upon by the Revenue lacked a Document Identification Number, and the Court applied Circular No. 19/2019 dated 14.08.2019 to hold that a document issued without DIN is invalid and is to be treated as never having been issued. On that basis, the sanction could not support the impugned order, making the order liable to be quashed and set aside.

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Issues: Whether the sanction relied upon by the Revenue was invalid for want of a Document Identification Number, and whether the impugned order could survive on the basis of such sanction.

Analysis: The sanction copy produced in the proceedings did not contain a Document Identification Number. The Court applied the requirement reflected in Circular No. 19/2019 dated 14.08.2019 and followed its earlier view that a document issued without compliance with the DIN requirement is invalid and is to be treated as never having been issued. On that basis, the sanction could not be relied upon for sustaining the impugned order.

Conclusion: The sanction was invalid for want of DIN, and the impugned order was liable to be quashed and set aside.

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