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The Appellant here wishes to draw attention towards CBDT's Circular No. 19/ 2019 (copy of the circular enclosed at pages 189-190 of the paperbook) which mandates that all communications issued by income tax authorities on or after 01.10.2019 shall mandatorily have a computer-generated DIN which should be duly quoted in the body of such communication.

Relevant excerpt from the CBDT Circular is reproduced hereunder:

8.3 Further there is no merit in the argument of the Ld. AR that as the DIN no. has been generated on 18.12.2019 whereas assessment order has been passed on 17.12.2019, the assessment order was bad in law. The objective behind mandatory requirement of generation and quoting of computer generated no.

DIN no. in various notices, orders or correspondence issued by the Income Tax Department is to maintain proper audit trail of all such communications. It is clearly mentioned in para no. 2 of circular no. 19/2019 that no communication shall be issued by the Income Tax Authorities on or after 01.10.2019 unless a computer generated DIN has been allotted and is duly quoted in the body of such communication. Therefore the AO was to generate such DIN no. before issuing/ communicating such assessment order along with demand notice to the appellant. It is observed that the AO has complied with the requirement of circular no. 19/2019 by generating the DIN no. through the ITBA portal on 17.12.2019 and quoting the same in the body of demand notice before uploading the same for communication to the appellant on 17.12.2019 electronically. The AO has uploaded the said reassessment order on the assessment module of the ITBA portal on 17.12.2019 after incorporating DIN no. which is also appearing in the screen shot of the portal of the AO, reproduced as above. Merely because the DIN no has been mentioned manually in the demand notice would not make it invalid. Though the AO has not mentioned the DIN no in the body of the assessment order, however such omission on the part of the AO is covered by the provision of section 292B of the Act as such assessment order was in substance and effect in conformity with or according to the intent and purpose of this Act.

14. In paragraph 5 of the aforesaid circular, the CBDT has talked about the steps to be taken by the income tax authority to regularize the manual communication within a period of 15 days by way of uploading the manual communication on the system, generating the DIN on the system and communicating the DIN so generated to the assessee.

15. In the instant case, on perusal of the reassessment order passed u/s 143(3) r/w 147 of the Act by the Deputy Commissioner of Income Tax, Central Circle 1, Chandigarh dated 17/12/2019, it is noted that there is no mention of any computer generated DIN which is allotted for the said communication and no DIN has thus been quoted in the body of reassessment order so issued. The communication so issued is thus not in compliance with paragraph 2 of the aforesaid circular issued by the CBDT.

CIRCULAR NO.19/2019 (F. NO.225/95/2019-ITA.II], DATED 14-8-2019 With the launch of various e-governance Initiatives, Income tax Department is moving toward total computerization of its work. This has led to a significant improvement in delivery of services and has also brought greater transparency in the functioning of the tax-administration Presently, almost all notices and orders are being generated electronically on the Income Tax Business Application (ITBA) platform. However, it has been brought to the notice of the Central Board of Direct Taxes (the Board) that there have been some instances in which the notice. order, summons, letter and any correspondence (hereinafter referred to as "communication" were found to have been issued manually, without maintaining a proper audit trail of such communication. 2. In order to prevent such instances and to maintain proper audit trail of all communication, the Board in exercise of power under section 119 of the income-tax Act, 1961 (hereinafter referred to as "the Act"), has decided that no communication shall be issued by any income-tax authority relating to assessment, appeals, orders, statutory or otherwise, exemptions, enquiry. investigation, verification of information, penalty, prosecution, rectification, approval etc. to the assessee or any other person, on or after the 1st day of October, 2019 unless a computer- generated Document Identification Number (DIN) has been allotted and is duly quoted in the body of such communication.