Absence of DIN Not Fatal if RFN Generated | HC

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GST order without DIN validity

Case Details: Kudos Facililty Services vs. State of Andhra Pradesh [2026] 183 taxmann.com 604 (Andhra Pradesh)

Judiciary and Counsel Details

  • R. Raghunandan Rao & T.C.D. Sekhar, JJ.
  • M. Ravindra for the Petitioner.

Facts of the Case

The petitioner, a registered dealer engaged in supply of manpower services, was subjected to assessment proceedings for the tax period 2019-20. A pre-show cause notice in Form GST DRC-01A and a show cause notice in Form GST DRC-01 were issued alleging discrepancies in returns. As no objections were filed, an assessment order dated 12.06.2024 was passed and uploaded on the GST portal. The petitioner preferred an appeal, which was rejected. Thereafter, recovery proceedings were initiated by issuance of attachment notice in Form GST DRC-16. Challenging the assessment order and consequential proceedings, the petitioner filed a writ petition contending that the assessment order did not contain a Document Identification Number (DIN) and that the pre-show cause notice and show cause notice were invalid for want of signatures.

High Court Held

The High Court held that the petitioner was aware of the assessment proceedings and had failed to explain the delay in approaching the Court. The assessment order contained an auto-generated Reference Number (RFN), which is generated only upon digital signing of the order while uploading it on the GST portal. The Court observed that show cause notices and summary of assessment orders issued electronically cannot be generated without digital signatures, and affixture of such digital signature automatically results in generation of a unique identification number. Therefore, presence of the RFN/reference number was sufficient to establish valid authentication. The contention regarding absence of DIN or signature was rejected, and the writ petition was dismissed in favour of the Revenue.

List of Cases Reviewed

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied