Clauses 26 and 106 of the Finance Bill, 2026 introduce targeted clarificatory amendments to address litigation surrounding the quoting of the computer-generated Document Identification Number (DIN) in income-tax assessment orders.
The amendments ensure that assessments are not annulled for minor or technical defects in DIN quoting, where a valid DIN exists and the assessment order is referenced by such DIN in any manner.
To achieve uniformity across tax regimes, the Bill:
- Inserts a new section 292BA in the Income-tax Act, 1961, with retrospective effect, and
- Inserts a corresponding provision in section 522 of the Income-tax Act, 2025, effective prospectively.
Background: DIN Requirement and Judicial Controversy
Purpose of DIN
The requirement to quote a computer-generated DIN was introduced by CBDT Circular No. 19/2019 dated 14 August 2019, with effect from 1 October 2019, to ensure:
- electronic traceability,
- transparency, and
- accountability of tax administration.
Issue That Emerged
Despite the presence of section 292B (which saves proceedings from invalidation due to technical defects), courts in certain cases:
- invalidated assessments where DIN was:
- not mentioned on every page,
- not reflected in the body of the order, or
- mentioned only in a covering communication, even though a valid DIN had been generated.
This led to assessments being quashed on procedural technicalities, rather than on jurisdictional or substantive defects.
Clause 26: Insertion of Section 292BA (Income-tax Act, 1961)
What Does Section 292BA Provide?
Clause 26 inserts section 292BA, which specifically addresses DIN-related issues for assessment orders. It provides that:
No assessment shall be invalid or deemed to be invalid merely due to any mistake, defect or omission in quoting the computer-generated DIN, if the assessment order is referenced by such DIN in any manner.
Key Points of Interpretation
- The protection applies only to assessments, not to all proceedings
- The DIN must exist and be referenced, complete absence of DIN is not cured
- The provision operates in addition to, and not in substitution of, section 292B
Retrospective Effect
- Applies retrospectively from 1 October 2019,
- i.e. the date from which DIN compliance became mandatory.
This retrospective operation is intended to neutralise litigation arising after introduction of DIN.
Clause 106: Corresponding Amendment in the Income-tax Act, 2025
What Does Clause 106 Do?
Clause 106 inserts sub-section (2) in section 522 of the Income-tax Act, 2025. It provides that:
No assessment under the Act shall be invalid merely due to any mistake, defect or omission in quoting DIN, if the assessment order is referenced by such DIN in any manner.
This provision mirrors section 292BA of the 1961 Act and ensures continuity under the new law.
Effective Date
- Applicable from 1 April 2026,
- i.e. from the commencement of the Income-tax Act, 2025.
Why a Separate Section Was Inserted
- Section 292B is a general saving provision
- Section 292BA (and section 522(2)) provide a specific statutory rule for DIN-related defects
- The legislature chose clarity over reliance on judicial interpretation
This approach reduces scope for further litigation on DIN technicalities.
What the Amendments Do and Do Not Do
What They Do
- Protect assessments from annulment due to minor DIN-quoting defects
- Reinforce the principle of substance over form
- Restore legislative intent behind DIN implementation
What They Do Not Do
- ❌ Do not validate assessments lacking jurisdiction
- ❌ Do not cure absence of DIN altogether
- ❌ Do not relax the requirement to generate DIN
- ❌ Do not apply to non-assessment proceedings beyond what is stated
The amendments apply only where a DIN exists and is referenced.
Effective Dates at a Glance
| Provision | Statute | Effective Date |
| Section 292BA | Income-tax Act, 1961 | Retrospective from 1 October 2019 |
| Section 522(2) | Income-tax Act, 2025 | 1 April 2026 |
Conclusion
Clauses 26 and 106 of the Finance Bill, 2026 provide a precise and limited clarification to prevent income-tax assessments from being invalidated on purely technical DIN-related grounds, while fully preserving the integrity and purpose of the DIN framework.
By aligning the legacy and new tax statutes, the amendments significantly reduce avoidable litigation and reaffirm that procedural requirements should support transparency, not defeat otherwise lawful assessments.
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