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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.”

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