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Issues: Whether an order initially communicated electronically without a Document Identification Number (DIN), followed immediately by an intimation correctly communicating the DIN and enclosing the order with a manually entered DIN, satisfies Circular No. 19/2019 dated 14.08.2019; and whether an incorrect manual DIN entry invalidates the order.
Analysis: Circular No. 19/2019 makes DIN mandatory to secure authenticity and an audit trail of departmental communications. The prescribed ITBA mechanism for manually prepared orders entails uploading the order to generate a DIN; the upload may automatically communicate the order before DIN generation, after which an intimation bearing its own DIN and specifying the DIN assigned to the order is issued with the order. This electronic process is distinct from manual issuance without DIN and does not require prior approval of the Chief Commissioner or Director General. Read purposively with Instruction No. 5 dated 25.10.2019, the procedure sufficiently preserves the identity, traceability and authenticity of the orders. A mistaken manual insertion of the intimation-letter DIN instead of the order DIN is a typographical error where the accompanying intimation correctly identifies the order and its DIN.
Conclusion: The DIN requirement is mandatory, but subsequent electronic communication of the correct DIN through an authenticated intimation constitutes sufficient compliance; an order is invalid only where no DIN is generated or communicated. An incorrect manually entered DIN does not invalidate the order when the accompanying intimation correctly states the order's DIN. The issue is decided in favour of the Revenue.