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DRP directions without a valid computer-generated Document Identification Number (DIN) allotted and quoted in the body of the order are invalid and deemed never issued. CBDT Circular No.19/2019 applies to DRP orders, even if considered internal communication or DRP not an income-tax authority under the Act. DRP falls under "all other persons employed in the execution of this Act" bound by CBDT circulars u/s 119. The circular applies irrespective of electronic or manual order generation. Non-generation of DIN invalidates DRP directions, rendering the final assessment order by the AO time-barred u/s 144C(13) and Section 153(2) proviso. An illegal order remains in operation until set aside on appeal. Hence, the impugned DRP/AO orders without valid DIN are invalid, non-est, and liable to be quashed.
DRP directions without a valid computer-generated Document Identification Number (DIN) allotted and quoted in the body of the order are invalid and deemed never issued. CBDT Circular No.19/2019 applies to DRP orders, even if considered internal communication or DRP not an income-tax authority under the Act. DRP falls under "all other persons employed in the execution of this Act" bound by CBDT circulars u/s 119. The circular applies irrespective of electronic or manual order generation. Non-generation of DIN invalidates DRP directions, rendering the final assessment order by the AO time-barred u/s 144C(13) and Section 153(2) proviso. An illegal order remains in operation until set aside on appeal. Hence, the impugned DRP/AO orders without valid DIN are invalid, non-est, and liable to be quashed.
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