The Rajasthan High Court has held that a GST order generated through the common portal does not become invalid merely because it does not contain a Document Identification Number (DIN), provided it bears a verifiable Reference Number (RFN).
The Bench of Justice Arun Monga and Justice Sunil Beniwal observed that an RFN generated through the GST portal serves the same purpose of authenticity and traceability as a DIN and is therefore sufficient compliance with the statutory framework.
The petitioner/assessee sought quashing of the order primarily on the ground that it did not contain a DIN, which was claimed to be mandatory under CBIC Circular Nos. 122/41/2019-GST and 128/47/2019-GST.
The proceedings arose from an investigation conducted by CGST authorities which was allegedly found to be a dummy proprietary concern controlled by the petitioner. During the investigation, searches were conducted under Section 67 of the CGST/RGST Act at the petitioner’s residence and business premises.
According to the department, the petitioner had wrongfully availed Input Tax Credit (ITC) amounting to ₹32.29 crore without actual receipt of goods or services. The authorities further alleged that fraudulent ITC amounting to ₹30.97 crorehad been passed on through 32 fictitious entities allegedly created and operated by the petitioner.
Following investigation, a show cause notice dated June 30, 2025 was issued, to which the petitioner submitted a reply. Although proceedings initiated under Section 61 of the CGST Act were dropped separately, the department subsequently passed the impugned penalty order dated December 9, 2025.
The principal argument advanced by the petitioner was that the impugned order was void ab initio because it did not contain a Document Identification Number (DIN).
The petitioner relied upon earlier CBIC circulars mandating the generation and quoting of DIN in departmental communications and contended that any communication issued without DIN is deemed never to have been issued. It was also argued that the exceptions permitting issuance without DIN were inapplicable, as neither reasons had been recorded nor any declaration was made in the impugned order.
The petitioner relied on judicial precedents including G. Bhaskar Reddy v. Assistant Commissioner and the Supreme Court’s decision in Pradeep Goyal v. Union of India to contend that the absence of DIN rendered the order non est in law.
The department opposed the writ petition on two principal grounds.
First, they contended that the petitioner had an effective statutory appellate remedy under the GST law and ought not to have invoked the extraordinary writ jurisdiction of the High Court.
Secondly, they submitted that although the order did not expressly mention a DIN, it contained a unique Reference Number (RFN) “I/3740446/2025”, which was electronically verifiable through the GST portal. The respondents demonstrated before the Court that entering the RFN on the CBIC/GST portal successfully retrieved the impugned order, thereby establishing its authenticity and traceability.
The Court observed that the facts of the present case were distinguishable from the precedents relied upon by the petitioner. Unlike those cases, the impugned GST order carried a unique RFN that was capable of electronic verification through the GST portal.
The Bench held that the RFN fulfilled the very purpose for which DIN was introduced, namely ensuring transparency, authenticity and traceability of official communications.
The Court further referred to Section 169 of the Central Goods and Services Tax Act, 2017, which prescribes the valid modes of service of notices, orders and communications. The provision recognises service through the common GST portal, registered post and email.
Since the impugned order had been uploaded on the GST portal and had also been dispatched through registered post as well as email, the statutory requirements regarding communication of the order stood fully satisfied.
The Court emphasised that even assuming there had been no DIN or RFN, the absence of such identification alone would not invalidate an order that had otherwise been duly communicated through statutorily recognised modes under Section 169.
A significant aspect of the judgment was the Court’s reliance on the CBIC Circular dated June 9, 2025, which clarified the legal position regarding DIN and RFN.
The circular explains that communications generated through the GST common portal automatically bear a Reference Number (RFN) that is electronically verifiable. Since such communications already contain a unique electronic identifier, requiring a separate DIN would unnecessarily duplicate the identification mechanism.
The circular expressly clarifies that communications generated through the GST portal bearing a verifiable RFN do not require a DIN and shall be treated as valid communications. The Court observed that this circular effectively modified the earlier CBIC circulars on mandatory DIN quoting.
Accordingly, the Court held that an RFN performs the same functional role as a DIN in ensuring traceability and authenticity.
Finding no merit in the petitioner’s challenge, the High Court dismissed the writ petition.
However, the Bench granted limited relief by observing that since the writ petition had been filed within the statutory limitation period prescribed for filing an appeal, the time spent prosecuting the writ petition would stand excluded while computing limitation if the petitioner chooses to avail the statutory appellate remedy.
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