DIN compliance: omission of Document Identification Number can render tax orders procedurally noncompliant under CBDT Circular.
The dispute focuses on whether omission of the Document Identification Number (DIN) from a substantive tax order, despite issuance of an intimation letter containing the DIN, renders the communication noncompliant with CBDT Circular No.19/2019; the Tribunal treated a DIN-less order as deficient, rejected the revenue's rectification attempts and allowed relief to the assessee, while the High Court found no substantial question of law warranting interference, underscoring strict procedural adherence in tax communications.