2022 (10) TMI 1195

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.... Nishnk Vashisht, Advs. For the Respondent : Shri Kanv Ball, Sr. DR ORDER PER SAKTIJIT DEY, JUDICIAL MEMBER: Captioned applications have been filed by the assessee seeking stay on recovery of the following outstanding demands: Assessment Year: 2017-18 Rs.253,04,85,102 Assessment Year: 2018-19 Rs.310,63,51,155 2. Shri Kamal Sawhney, learned counsel appearing for the assessee, submitted....

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....n 27th September 2022. Therefore, the assessment orders are grossly barred by limitation. Proceeding further, he submitted, the final assessment orders do not contain DIN which is mandatory as per Circular No. 19/2019 dated 14th August, 2019 issued by the Central Board of Direct Taxes (CBDT). He submitted, the conditions prescribed in the said circular regarding manual issue of orders/documents wi....

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....is observed that DIN has not been mentioned. Therefore, as per the extant CBDT circular, referred to elsewhere in the order, such orders are to be declared as non est and never been issued. Though, we agree with learned Departmental Representative that these aspects have to be thrashed out by the parties at the time of full length hearing of the appeals, however, there is good ground for grant of ....