Document Identification Number

The Income Tax authorities communicate with the assessee in the form of assessment, appeal, investigation, penalty, prosecution, rectification etc. Previously all the communication by the Income Tax authorities with the assessee/any other person used to be in the paper form. However, presently, almost all the communications like notices and orders are being generated electronically on the Income Tax Business Application Platform. In spite of the facility to communicate electronically, some instances have been noticed, wherein, the communication like income tax notices, orders, letter, summons or any other correspondence has been manually supplied to the assessee. In order to stopover the manual communication and with the intention to ensure a proper audit trail of the departmental communication, each communication issued by the Income Tax Department will now be assigned a separate computer generated Document Identification Number. Clarifying on the same, recently, on 14^th August 2019, circular no. 19/2019 (Refer below) was issued by the Central Board of Direct Taxes (CBDT). Under the present article, we would try to understand the Document Identification Number; objective for introducing the Document Identification Number; List of exceptions and also a consequence of non-quoting of Document Identification Number.

Understanding Document Identification Number

The Income-tax department communicates with the assessee or any other person via various communication means like the letter, orders, summons, notice and any other correspondence. On or after 1^st October 2019, it gets mandatory for the income tax department authorities to generate computerised Document Identification Number and quote the same clearly on the body of the document. In other words, each and every communication from the income tax departmental front should carry a unique computer-generated ‘Document Identification Number’. As per latest notification on 5th November 2019, the inclusion of DIN in every communication of the income tax department, it is effective from 8th November 2019. Please find the respective notification below:

The objective for the introduction of mandatory Document Identification Number

Following are the basic objective for introduction of the mandatory provision of quoting of Document Identification Number:

Improvement in delivery of the service.
Complete transparency in the functioning of the tax administration.
Total computerisation of the work.
Maintaining a proper audit trail.

List of Exceptions

With the prior written approval of the Director-General or Chief Commissioner of the Income Tax and after a recording of the reasons in writing in the file, the communication can be issued manually only under the following circumstances:

In case there is any technical difficulty in generating or quoting the DIN and further issuance of communication, electronically.
In case the functionality to issue the communication is not available/existing in the system.
In case the PAN is not available with the assessee and proceedings under the Income Tax Act is initiated against the assessee. However, verification under section 131 or under section 133 of the Income Tax Act is not covered here.
If the communication relating to any inquiry or verification is required to be issued by any income-tax authority, who is outside the office for discharging his official duties.
In case of delay in PAN migration, the PAN is lying with non-jurisdictional Assessing Officer.

Non-quoting of Document Identification Number

In case the income tax departmental officers fail to comply with the requirement of quoting of Document Identification Number, then, any such communication which is lacking Document Identification Number would be treated as invalid. It shall be deemed that such communication has never been issued by the officer.

Action for the already issued manually correspondence

The circular provides the specific system to be followed by the Income Tax authorities for all the pending assessment proceedings, wherein, manual correspondence is done:

The Income Tax authorities are required to identify such cases; and
The authorities are required to upload the manually issued notices/correspondence of such cases in the system by 31st October 2019.

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