CIT (International Taxation) v. Sutherland\nGlobal Services Inc.

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. EI RESORTS & CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon‟ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. E I RESORTS AND CLUBS PVT LTD, MUMBAI

3213/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon‟ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

EI BENEFICIARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon'ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

EI BENEFICARY TRUST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

3230/Mum/2025 Govind

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon‟ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

GOVIND CORPORATION,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

GOVIND CORPORATION ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon'ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

VEDA REAL ESTATE CORPORATION PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

EI RESORTS AND CLUBS PVT LTD ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

DCIT, CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PVT LTD, MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

3012/Mum/2025

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon‘ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

…atory, and that even if a DIN was generated later and handwritten in the order, such post facto insertion could not cure the inherent defect of invalidity. The reasoning was reiterated in CIT (International Taxation) v. Sutherland Global Services Inc. [(2025) 175 Taxmann.com 897 (Mad)], where the Hon'ble Court observed that the absence of a pre- generated DIN, or the failure to record reasons and obtain prior approval for manual issuance, is fatal to the validity of the order. These rulings, when read conjointly, leave no room for doubt that compliance with the DIN protocol is a jurisdictional prerequisite and no…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DCIT CENTRAL CIRCLE 8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

DCIT CENTRAL CIRCLE-8(1), MUMBAI, MUMBAI vs. THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED, MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…

THE ESTATE INVESTMENT COMPANY PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE -8(1), MUMBAI

…y, and that even if a DIN was generated\nlater and handwritten in the order, such post facto insertion\ncould not cure the inherent defect of invalidity. The reasoning\nwas reiterated in CIT (International Taxation) v. Sutherland\nGlobal Services Inc. [(2025) 175 Taxmann.com 897 (Mad)],\nwhere the Hon'ble Court observed that the absence of a pre-\ngenerated DIN, or the failure to record reasons and obtain\nprior approval for manual issuance, is fatal to the validity of\nthe order. These rulings, when read conjointly, leave no room\nfor doubt that compliance with the DIN protocol is a\njurisdictional prerequisite…