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July 2025

Section 144C(5): Document Identification Number [‘DIN’] – Circular No.19/2019 [F.No.225/95/2019-ITA II] dated 14.08.2019 – DIN has to be generated for DRP proceedings :

By Ajay R. Singh, Advocate
Reading Time 4 mins

8 Commissioner of Income Tax, International Taxation vs. M/s. Laserwords US Inc.,

[T.C.A. No. 46 OF 2025 and CMP Nos. 5208 and 5211 of 2025 Dated: 10/06/2025, (Madras) (HC).]

[ Arising out of ITAT: “D” Bench, Chennai, dated 22.12.2023 passed in IT (TP) A.No.44/CHNY/2021 for the AY 2015-16.]

Section 144C(5): Document Identification Number ['DIN'] - Circular No.19/2019 [F.No.225/95/2019-ITA II] dated 14.08.2019 – DIN has to be generated for DRP proceedings :

The ITAT by impugned order held that the direction issued by the Dispute Resolution Panel ['DRP'] under Section 144C(5) of the Act did not contain a Document Identification Number ['DIN'] as mandated by the Central Board of Direct Taxes by its Circular No.19/2019 [F.No.225/95/2019-ITA II] dated 14.08.2019. The subsequent communication intimating the DIN for DRP proceedings did not satisfy the conditions prescribed in paragraph No.3 of the said circular. Accordingly, the said directions were invalid in law and as a sequitur, the assessment order which was impugned before the ITAT was liable to be quashed. In the instant case, the assessment order also did not contain a DIN.

The counsel f

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