The Supreme Court has declined to interfere with an Andhra Pradesh High Court ruling that the presence of a system-generated Reference Number on an electronically issued GST order is sufficient to establish that the document was digitally signed.
A Division Bench of Justice Dipankar Datta and Justice Sheel Nagu dismissed the Special Leave Petition filed against the High Court’s judgment concerning a GST demand raised against a stone-crushing business.
“We are not inclined to interfere with the impugned judgment and order of the High Court,” the Supreme Court recorded in its order dated September 2, 2026.
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The proceedings arose from a GST assessment order dated April 29, 2024, issued in Form GST DRC-07 under Section 73 of the Goods and Services Tax Act, 2017, for the financial year 2018-19.
The taxpayer had challenged the validity of the assessment primarily on the ground that the order did not carry a Document Identification Number and did not display the signature of the issuing authority. It consequently argued that the assessment was void and unenforceable.
The taxpayer, a registered dealer engaged in the stone-crushing business, had received a show-cause notice in Form GST DRC-01 on January 30, 2024. The notice proposed the disallowance of Input Tax Credit relating to the period from January 2019 to March 2019.
A reply to the notice was submitted on March 12, 2024. After considering the response, the jurisdictional GST authority passed the assessment order on April 29, 2024.
The order reportedly imposed tax of ₹9,69,042, interest of ₹5,60,183 and a penalty of ₹96,904. The aggregate liability was approximately ₹16.26 lakh.
According to the taxpayer, it became aware of the assessment only upon receiving a recovery notice dated November 21, 2025, directing it to discharge the tax, interest and penalty. It thereafter downloaded the assessment order from the GST portal and approached the Andhra Pradesh High Court.
The taxpayer relied upon CBIC Circular No. 122/41/2019-GST dated November 5, 2019, which prescribes the generation and quoting of a DIN on specified communications issued by tax authorities.
It contended that the assessment order was invalid because it neither mentioned a DIN nor contained the visible signature of the officer. The taxpayer sought the quashing of the DRC-07 proceedings on grounds including violation of natural justice, limitation and absence of proper authentication.
The State opposed the petition, pointing out that both the show-cause notice and the assessment order had been uploaded to the GST portal on the respective dates of their issuance.
It was also submitted that the taxpayer had participated in the assessment proceedings by filing objections in March 2024. Despite knowing that the proceedings were pending, it did not take timely steps to ascertain the outcome or challenge the assessment until the recovery notice was issued in November 2025.
The Andhra Pradesh High Court rejected the argument that the order was invalid for want of a DIN or signature.
The Court found that the DRC-07 order carried the Reference Number. It observed that this number was generated automatically by the GST system when the assessment order was uploaded to the portal and was exclusively assigned to the order in question.
Relying on its earlier decisions, the High Court explained that a show-cause notice in Form GST DRC-01 and a summary assessment order in Form GST DRC-07 are issued electronically. Such documents cannot be electronically issued through the portal unless the issuing authority digitally signs the proceedings.
The affixing of a digital signature results in the automatic generation of an identification number known as the Reference Number or RFN. The High Court held that the presence of an RFN was sufficient to conclude that a digital signature had been affixed to the document.
Accordingly, the mere absence of a separately displayed DIN or a conventional visible signature on the downloaded copy did not render the electronic GST order invalid.
The Court also noted that the GST portal had undergone procedural changes concerning the manner in which orders were uploaded and identification numbers were displayed. Since the disputed order contained a unique RFN, it could not be treated as an unidentified or unauthenticated communication.
Apart from rejecting the taxpayer’s objections on the merits, the High Court held that the writ petition suffered from unexplained delay and laches.
The assessment order had been passed and uploaded on April 29, 2024. However, the taxpayer approached the High Court only after receiving the recovery communication in November 2025.
The Court found it significant that the taxpayer had filed a reply to the show-cause notice on March 12, 2024. Its participation established that it was aware of the assessment proceedings.
Despite this knowledge, the taxpayer did not explain why it had failed to monitor the GST portal or take steps to ascertain the outcome of the proceedings for more than a year.
Describing the absence of any explanation as a material omission, the High Court held that the petition could not be entertained after such an unexplained delay. It dismissed the writ petition without costs.
The taxpayer challenged the High Court’s judgment by filing Special Leave Petition (Civil) No. 22475 of 2026 before the Supreme Court.
After hearing the taxpayer’s counsel, the Supreme Court refused to interfere and dismissed the petition. All pending interlocutory applications were also disposed of.
The Supreme Court’s brief order does not independently analyse the DIN or digital-signature issue. Nevertheless, its refusal to interfere leaves undisturbed the High Court’s conclusion that an electronically generated RFN can establish the digital authentication of a GST order even when the downloaded document does not display a separate DIN or visible signature.
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