CBDT issues revised DIN norms, replaces 2019 circular on tax notices

New guidelines introduce flexibility in quoting DIN in tax communications while ensuring traceability and reducing litigation over procedural lapses

The Central Board of Direct Taxes (CBDT) on Tuesday issued fresh guidelines on the use of Document Identification Number (DIN) in income-tax communications, replacing the 2019 circular.

 

The new circular has been issued under Section 119 of the Income-tax Act, 1961, and takes into account Section 292B as well as the newly inserted Section 292BA. It also aligns with similar provisions under the Income-tax Act, 2025.

 

Under the circular, every notice, letter, order, draft order, summons, or any other communication issued by an income-tax authority to a taxpayer must carry a computer-generated DIN. However, the CBDT has clarified that the DIN need not appear on every page. It can be mentioned in the email or provided through a separate document attached to the communication.

 

 

The requirement applies to communications issued to any person other than internal officers, as specified under Section 116 of the Act. Public communications such as guidelines and FAQs are not required to carry a DIN.

 

The circular also allows certain exceptions where a communication may be issued without a DIN. These include cases where there are technical difficulties, where electronic issuance is not possible, when an officer is outside the office and does not have access to the system, delays in PAN migration where the PAN lies with a non-jurisdictional assessing officer, cases where PAN is not available, and where the required functionality is not available in the IT system.

 

In all such cases, the communication must clearly state the reason for not quoting the DIN.

 

The CBDT has said that such communications will require post-facto approval within 15 days from a competent authority. For officers below the rank of Joint Commissioner or Joint Director, approval will be required from the Joint/Additional Commissioner or Director. In other cases, approval will be required from the Chief Commissioner or Director General.

 

Further, communications issued in certain exceptional cases must be uploaded on the IT system with proper DIN within 15 working days.

 

The earlier Circular No. 19/2019, which had made DIN mandatory without detailing such exceptions, has been withdrawn with immediate effect.

 

The DIN system was introduced in October 2019 to improve transparency and create an audit trail in tax communications. However, several High Courts had quashed notices and orders on technical grounds where DIN was not properly quoted.

 

To address this, the Finance Act, 2026 inserted Section 292BA with retrospective effect from October 1, 2019. The provision states that a notice or order will not become invalid merely due to any mistake or omission in quoting the DIN, as long as the DIN has been generated and can be linked to the communication.

 

Manish Garg, partner – tax, AKM Global, said, “Under the new circular, the CBDT has laid down updated guidelines specifying how and when DIN is to be referenced in all communications issued by an income-tax authority… While the requirement of generating and quoting DIN continues as a general rule to ensure traceability and transparency, the circular introduces a more flexible approach…”

 

“From the perspective of the tax department… the revised framework aims to reduce litigation arising from technical defects… However, from the perspective of taxpayers… taxpayers can no longer rely on DIN-related defects as a primary defence… the focus of disputes will now decisively move from procedural lapses to substantive merits,” he further added.