Andhra High Court upholds GST order despite missing DIN on physical copy

Court rules GST order issued through portal with system-generated reference number remains valid even if physical copy does not carry Document Identification Number

The Andhra Pradesh High Court has upheld a goods and services tax (GST) assessment order issued against Kudos Facility Services, ruling that the absence of a Document Identification Number (DIN) on the physical copy does not invalidate an order issued by the tax department electronically through the GST portal if it carries a system-generated reference number.

 

A division bench of Justices Rao Raghunandan Rao and T C D Sekhar, in the order dated February 9, held that the reference number generated on the portal is sufficient to establish that the order was digitally authenticated.

 

The case is related to a 2019–20 GST dispute. The tax department had initiated proceedings after flagging discrepancies in the firm’s returns and later passed the assessment order when no response was filed.

 

The petitioner argued that the order was invalid as it did not carry DIN, as required under a 2019 GST circular, and also claimed that the notices were not properly signed. However, the court rejected the contention, holding that the portal-based digital system itself provides adequate authentication.

 

The DIN requirement was introduced through a 2019 GST circular to improve traceability and accountability in departmental communications. However, tax experts said the later shift towards portal-based authentication reflects the government’s growing reliance on the GST system’s built-in digital safeguards.

 

The court's decision comes alongside Budget 2026’s insertion of Section 292BA in the Income Tax Act, which retrospectively validates direct tax orders issued from October 2019 despite DIN-related errors, provided the DIN was properly generated.

 

Ikesh Nagpal, lead-Indirect Tax, AKM Global, said the DIN requirement has evolved in “layers”. “The 2019 circular introduced DIN as a mandatory safeguard to enhance transparency and traceability in tax communications. The subsequent 2025 circular diluted that requirement in the GST context, recognising the robustness of portal-based digital authentication,” he said.

 

Now, the Andhra Pradesh HC with this judgment affirming the sufficiency of system-generated RFNs and digital signatures, the legal position appears settled at least prospectively, Nagpal stated.

 

“That said, the regulatory journey can feel less than linear. When a safeguard is first made mandatory and later withdrawn, it inevitably raises questions on consistency and expectations. The court’s ruling, however, signals a broader shift and great clarity on where the statutory digital framework itself ensures authenticity and traceability, procedural form should not eclipse substantive compliance,” he added.