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HC upheld ITAT's decision quashing assessment orders passed u/s 144C(13) following invalid DRP proceedings. The DRP communication failed to comply with prescribed circular requirements as the DIN was handwritten without specified reasons, lacked prior Chief Commissioner approval, and contained interpolated DIN numbers suggesting post-facto generation. The court found DIN ending 1048143460(1) in DRP proceedings dated 19.12.2022 could not have been generated on 21.12.2022, indicating fraudulent interpolation. Assessment orders based on invalid DRP directions were deemed unsustainable. Revenue department was held responsible for non-compliance with departmental circulars. HC imposed costs of Rs. 1,00,000 payable to PM CARES Fund for the false claims made by appellant regarding DIN generation.
HC upheld ITAT's decision quashing assessment orders passed u/s 144C(13) following invalid DRP proceedings. The DRP communication failed to comply with prescribed circular requirements as the DIN was handwritten without specified reasons, lacked prior Chief Commissioner approval, and contained interpolated DIN numbers suggesting post-facto generation. The court found DIN ending 1048143460(1) in DRP proceedings dated 19.12.2022 could not have been generated on 21.12.2022, indicating fraudulent interpolation. Assessment orders based on invalid DRP directions were deemed unsustainable. Revenue department was held responsible for non-compliance with departmental circulars. HC imposed costs of Rs. 1,00,000 payable to PM CARES Fund for the false claims made by appellant regarding DIN generation.
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