INCOME TAX OFFICER, INTERNATIONAL TAXATION WARD-1(2), CHENNAI, CHENNAI vs. BHAGYASHREE JAIN, CHENNAI

The Revenue raised the following grounds of appeal : “1. Whether on the facts and in the circumstances of the case and in law, the Ld.CIT(A) is justified in quashing the impugned order u/s 143(3) r.w.s 147 dated 24.10.2019 on account of it being issued without a DIN without appreciating the detailed process was followed while uploading the order in Income Tax Business Application (ITBA).

Briefly, the facts of the case are that the respondent assessee is an Individual. The Return of Income for the Assessment Year 2014-15 was filed on 31.07.2014 disclosing total income at Rs.2,09,52,200/-. Against the said Return of Income, the assessment was completed by the DCIT, Corporate Circle-2(1), Chennai(herein after called ‘AO’) vide order dated 24.10.2019 passed u/s.143(3) r.w.s 147 of the Income Tax Act, 1961 at a total income of Rs.2,18,17,707/-. Subsequently, the Assessing Officer formed an opinion that the income got escaped assessment from tax for the reason that the appellant received a sum of

Being aggrieved by the above assessment order, the appellant preferred an appeal before ld.CIT(A), who vide impugned order allowed the appeal on the ground that the assessment order does not contain the DIN Number following the decision of Jurisdictional High Court in the case of CIT Vs. Laserwords US Inc., 175 taxmann.com 920.

Being aggrieved, the Revenue is in appeal before us. When the appeal was called on, no one appeared on behalf of the respondent assessee despite due service of notice of hearing.

On the other hand, Learned Sr.DR submits that in view of the insertion of provisions of section 292BA with retrospective effect from 01.10.2019 by Finance Act, 2026, no assessment shall be invalid on account any mistake, defect or omission in respect of quoting DIN. The assessment order was quashed by the ld.CIT(A) for non-quoting of DIN Number, thus, it is invalid in view of the insertion of provisions of section 292BA of the Income Tax Act, 1961. Therefore, he submits that the assessment order may be restored to the file of ld.CIT(A) to decide adjudicate the issues in appeal on merit.

We heard ld.Sr.DR and perused the material on record. We find from the impugned order that the ld.CIT(A) annulled assessment order for non-quoting of DIN Number in the assessment order. The Parliament inserted the provisions of section 292BA by Finance Act, 2026 to clarify that no assessment shall be invalid on account of any mistake, defect, or omission in respect of non-quoting of DIN Number with retrospective effect from 01.10.2019. In view of the legislative amendment, we are of the considered opinion that the order of the ld.CIT(A) is required to be reversed and the matter is remitted back to the file of ld.CIT(A) for denovo disposal of issues in appeal in accordance with law after affording an opportunity of being heard to the respondent assessee.

In the result, appeal filed by the Revenue stands partly allowed for statistical purpose. Order pronounced in the open Court on 31st July, 2026.