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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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