Absence of DIN Not Fatal if RFN Generated | HC

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

• Pedda Masthan Enterprises v. Asstt. Commissioner (ST) [2026] 183 taxmann.com 108 (Andhra Pradesh) (para 11), followed

List of Cases Referred to

• Pedda Masthan Enterprises v. Asstt. Commissioner (ST) [2026] 183 taxmann.com 108 (Andhra Pradesh) (para 11).