Insurer's investment gains and investment write-downs face Section 263 revision; enquiry upheld, Rule 5(b)(ii) lapse sustained, late corrigendum quash...
The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
The central issue was whether the approval authorizing a special audit under s.142(2A) complied with Circular No.19/2019 by bearing a DIN and requisite manual-issuance justification; the court held the approval dated 06.02.2025 lacked a DIN and any exceptional-circumstances endorsement, violating the Circular and settled precedent that jurisdictional communications (including approvals/sanctions) must carry a DIN. Legal basis: Circular No.19/2019 and prior HC rulings invalidating DIN-less sanctions. Outcome: the approval is non est in law and the subsequent order directing a special audit is without jurisdiction - decided for the assessee. - HC
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