HC: Matter remanded as ITAT didn’t consider assessee’s argument on non-mentioning of DIN in assessment order { Skyway Infraprojects (P.) Ltd. vs. Dy./Asst. Commissioner of Income-tax, Central [2025] 176 taxmann.com 992 (Bombay)}
Facts: Skyway Infraprojects Pvt. Ltd. challenged assessment orders for AYs 2013–14 to 2020–21, arguing they were invalid as they lacked a mandatory Document Identification Number (DIN) under CBDT Circular No. 19/2019, and were also time-barred. The ITAT dismissed the appeals without dealing with these points.
Issue: Whether absence of DIN in assessment orders rendered them invalid, and whether ITAT erred in not considering this contention.
Held: The Bombay High Court held that ITAT failed to examine the DIN issue, which is mandatory, and remanded all appeals for fresh hearing, allowing both sides to raise all grounds.
