Rama Pashu Aahar (P) Ltd., engaged in a dispute against the Assessing Officer’s order for the assessment year 2017-18, has raised significant questions regarding procedural irregularities in the issuance of assessment orders under the IT Act, particularly focusing on the absence of a Document Identification Number (DIN).
The case originated from an assessment order that lacked a DIN, a requirement mandated by CBDT Circular No. 19/2019. This circular stipulates that post-October 1, 2019, no communication from the income tax authority, including assessment orders, should be issued without a DIN. The appellant argued that the absence of DIN rendered the order invalid and non-existent.
The tribunal considered the legal and procedural aspects surrounding the issuance of the order without a DIN. It highlighted that any deviation from the stipulated process must be backed by a documented reason and appropriate approvals, which were lacking in this case. Ultimately, the tribunal ruled that the assessment order was invalid, setting a precedent on the strict adherence to procedural requirements laid out by the CBDT.
This decision underscores the importance of compliance with procedural safeguards to ensure fairness and transparency in tax assessments. The ruling not only affects the parties involved but also serves as a critical reminder to all tax authorities about the adherence to legal norms and the consequences of their violation.
The case of Rama Pashu Aahar (P) Ltd. vs. ACIT highlights crucial aspects of administrative law in tax proceedings, emphasizing the enforceability of CBDT circulars and their impact on the validity of administrative actions.
Rama Pashu Aahar (P) Ltd. vs ACIT: The DIN Controversy and ITA 1456/DEL/2021
Manage the increasing number of hearings effortlessly by leveraging the legal AI revolution We are India's Leading revolutionary AI-powered legal platform where you can get enough insights into top cases and judgements.
Research Platform