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The HC held that both DRP directions and assessment orders were invalid due to absence of Document Identification Numbers (DIN). The court determined that DRP proceedings, conducted by a collegium of three Income Tax Commissioners, fell within the scope of the circular requiring DIN generation. The appellant failed to provide explanation for non-generation of DIN in the assessment order. Consequently, the HC found no merit in the appeal and answered the substantial questions of law unfavorably to the appellant, invalidating both the DRP directions and assessment order for non-compliance with DIN requirements under the applicable circular provisions.
The HC held that both DRP directions and assessment orders were invalid due to absence of Document Identification Numbers (DIN). The court determined that DRP proceedings, conducted by a collegium of three Income Tax Commissioners, fell within the scope of the circular requiring DIN generation. The appellant failed to provide explanation for non-generation of DIN in the assessment order. Consequently, the HC found no merit in the appeal and answered the substantial questions of law unfavorably to the appellant, invalidating both the DRP directions and assessment order for non-compliance with DIN requirements under the applicable circular provisions.
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