Please find attached an update on the recent ruling of Delhi High Court wherein it is held that any communication including communication of assessment order not bearing a Document Identification Number (“DIN”) is non-est in law. 

Delhi High Court ( in the case of CIT vs Brandix Mauritius Holdings Ltd ITA No 163/2023) upholds quashing of assessment order passed by the Delhi Bench of ITAT where AO has not quoted DIN in the assessment order. The High Court holds that CBDT Circular No 19/2019 dated 14th August, 2019 to the effect that ‘any communication without DIN shall be treated as invalid and shall be deemed to never have been issued is binding on the Revenue. The High Court further holds such omission of quoting DIN in the body of the communication will not be saved by Section 292B of the Act. Dismisses appeal filed by Revenue against the order of ITAT. Oral Order dictated in open court.