1

Commissioner (A) is not empowered to enhance income a new source of income vide 82ITR 9Trib) 176
1

It is assessee’s choice to select a method for determining FMV of shares vide 81 ITR (Trib) (SN) 78
1

No TP adjustment of trade receivables in case of a debt-free company vide 81ITR (Trib) (SN) 94
1

To accord registration as a charitable institution under income tax dominant purpose must be charitable and satisfies the conditions laid down us 2(15) vide 426ITR108 despite having non charitable ancillary objects meant to achieve the dominant purpose
1

Transactions with dubious entities is reason enough for case reopening vide 421ITR624

Significance of DIN

ByCA Gopal Nathani

Nov 23, 2023

Circulars of the Board bind the Income-tax Officer as well as those holding Administrative authority such as Commissioner, PrCIT/DIT etc. ( other than appellate authorities). It is because of this reason that a notice and order issued u/s263 by Pr CIT ( E) is challenged for not bearing any document identification number nor stating reasons for not issuing a document identification number with the order as required by Central Board of Direct Taxes Circular No. 19 of 2019, dated August 14, 2019 . The ITAT held that failure to comply with these requirements rendered the communication invalid and deemed never to have been issued. Interestingly this appeal has been won just on the following additional ground leaving aside merits of the case: “That the order passed by the learned Principal Commissioner of Income-tax is null and void as it fails to mention any document iden tification number on its body or adhere to Circular No. 19 of 2019 ([2019] 416 ITR (St.) 140 ) by the Central Board of Direct Taxes.”