GST Assessment Not Invalid Merely for Absence of DIN if Portal-Generated Reference Number Exists: Andhra Pradesh High Court

The Andhra Pradesh High Court has dismissed a writ petition challenging a GST assessment and subsequent recovery proceedings on the ground that the assessment order did not mention a Document Identification Number (DIN) and that prior show cause notices were allegedly unsigned. The bench of Justice R. Raghunandan Rao and Justice T.C.D. Sekhar held that where the GST portal generates a unique Reference Number (RFN) upon electronic issuance, the absence of a separately mentioned DIN does not render the proceedings invalid. The bench rejected the plea and upheld the tax authorities’ actions, also citing unexplained delay and laches on the part of the petitioner. The petitioner, a registered GST dealer engaged in providing manpower services to APSRTC, was subjected to assessment proceedings for the tax period 2019–2020. After discrepancies were noticed in returns, the department issued a pre-show cause notice in Form GST DRC-01A followed by a show cause notice in Form GST DRC-01, proposing tax, interest, and penalty. As no objections were filed, the assessing authority passed an assessment order on 12 June 2024 in Form GST DRC-07. The petitioner’s statutory appeal was later rejected in July 2025, following which recovery proceedings were initiated by issuing an attachment notice in Form GST DRC-16 under Section 79 of the CGST Act. Aggrieved, the petitioner approached the High Court under Article 226 of the Constitution. The principal challenge before the Court was that the assessment order did not contain a Document Identification Number (DIN) as required under CBIC Circular No. 122/41/2019-GST dated 5 November 2019. The pre-show cause and show cause notices were allegedly invalid as they did not bear physical or digital signatures. The assessment and recovery proceedings were therefore arbitrary and void in law. Rejecting these arguments, the Bench observed that the assessment order clearly carried a system-generated Reference Number (RFN), which is automatically assigned by the GST portal when an order is digitally signed and uploaded. The Court reiterated its earlier rulings holding that GST notices and orders are issued electronically through the portal and cannot be uploaded unless digitally signed by the issuing authority. The presence of an RFN itself establishes that a digital signature has been affixed. DIN and RFN are portal-generated identifiers, and the absence of the term “DIN” in the printed order does not invalidate the proceedings. The Bench relied on earlier judgments of the same High Court which clarified that procedural changes in the GST portal and standardisation of digital signatures must be taken into account while examining such challenges. Apart from rejecting the technical objections, the Court also found that the writ petition was liable to be dismissed on the ground of unexplained delay. It noted that the assessment order was passed in June 2024 and uploaded on the portal on the same day. The petitioner had earlier participated in proceedings by filing objections to an earlier notice, indicating full awareness of the assessment process. No satisfactory explanation was offered for the delay in filing the statutory appeal or for approaching the High Court only after attachment proceedings were initiated in December 2025. The Court held that such conduct clearly attracted the doctrine of laches, disentitling the petitioner from discretionary relief under Article 226. Finding no merit in any of the grounds raised, the Andhra Pradesh High Court dismissed the writ petition, upheld the validity of the assessment and recovery proceedings, and declined to interfere. No order as to costs was passed, and all pending applications were closed. Case Details Case Title: Kudos Facility Services Versus The State Of Andhra Pradesh Case No.: Writ Petition No: 2871/2026 Date: 09/02/2026 Counsel For Petitioner: M Ravindra Counsel For Respondent: GP Click Here To Read Order Read More: Historic 10-Day Raid on Odisha’s Boudh Distilleries Uncovers Rs. 352 Crore Cash, India’s Largest-Ever Single Seizure

GST Assessment Not Invalid Merely for Absence of DIN if Portal-Generated Reference Number Exists: Andhra Pradesh High Court

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