Document Identification Number compliance invalidated the appellate order, leading to remand for fresh consideration.

Absence of a Document Identification Number in the appellate order was treated as a mandatory defect under binding circulars, vitiating the communication. The later circular relieving DIN requirements for email communications was held inapplicable to the impugned order dated 05.11.2024, and the alternative Unique Issue Number requirement was also not met. On that basis, the appellate order was set aside and the matter remanded to the appellate authority for fresh consideration after hearing the petitioner.

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Issues: Whether the appellate order was invalid for want of a Document Identification Number, and whether the matter should be remanded for fresh consideration.

Analysis: The challenge was confined to the absence of DIN in the appellate order. The order proceeds on the basis that DIN requirements issued through binding circulars are mandatory, and that non-compliance vitiates the communication or order. The later circular relied upon by the Revenue, which relaxed the requirement in relation to email communications, was found to be inapplicable to the impugned order dated 05.11.2024 and, in any event, the alternative requirement of an Unique Issue Number was also not satisfied. The matter therefore required reconsideration by the appellate authority after hearing the petitioner.

Conclusion: The appellate order was set aside and the matter was remanded to the appellate authority for fresh consideration.

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