2023 (9) TMI 1324

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....ta Das De, Adv. For the Respondent : Mr. Abhratosh Majumdar, Sr. Adv., Mrs. Akshara Shukla, Adv. ORDER This appeal filed by the revenue under Section 260A of the Income Tax Act, 1961 (the Act) is directed against the order dated 18th July, 2022 and 5th April, 2023, passed by the Income Tax Appellate Tribunal, `B' Bench, Kolkata, in I.T.A. No. 238/Kol/2021 and M.A. No. 38/Kol/2022, for the asses....

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....integral pat of the order passed under Section 263 ? c) Whether in the facts and in the circumstances of the case the Tribunal was justified in law in not appreciating the fact that the DIN which was duly generated and communicated along with the order passed under Section 263 to the assessee was in compliance of the Circular No. 19/2019 dated 14.08.2019 issued by the CBDT ? d) Whether the Tri....

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.... paragraph 4 it has been stated that any communication which is not in conformity with Para 2 and Para 3 of the said Circular shall be treated as invalid and shall be deemed to have never been issued. The Tribunal on examination of the facts held that the requirement as mentioned in the Circular namely, quoting of the Document Identification Number, has not been followed and therefore allowed the ....