HC Holds GST Assessment Order Without DIN or RFN Invalid
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- Last Updated on 20 May, 2026

Case Details: Anne Lakshmana Rao vs. Assistant Commissioner - [2026] 186 taxmann.com 199 (Andhra Pradesh)
Judiciary and Counsel Details
- R. Raghunandan Rao & T.C.D. Sekhar, JJ.
-
S. Siva Kumari for the Petitioner.
Facts of the Case
The petitioner challenged an assessment order passed on the ground that the order did not contain a Document Identification Number (DIN) or RFN and was issued through the GST portal without any system-generated identification on its face. It was contended that the absence of DIN/RFN constituted a fundamental procedural defect vitiating the validity of the assessment order. The petitioner relied on the contention that such deficiency rendered the order was liable to be set aside under writ jurisdiction. The matter was accordingly placed before the High Court.
High Court Held
The High Court held that the absence of a DIN or RFN on the assessment order constituted an inherent and material defect, particularly when the order was issued through the GST portal without system-generated identification. It observed that the requirement of proper documentation and traceability of official communications flows from the mandatory procedural framework under GST, including Section 160 of the CGST Act and Andhra Pradesh GST Act, which governs validity of proceedings. The Court further noted that earlier binding precedents had already recognised that non-mention of DIN in departmental communications is sufficient to invalidate such orders under the statutory framework. Accordingly, the impugned assessment order was set aside and the matter was remanded for fresh adjudication.
List of Cases Reviewed
- Sathiah Ramesh v. Deputy Commissioner (State Tax) [2026] 183 taxmann.com 149 (Madras)/W.P. No. 1474 of 2026 (para 11) followed
List of Cases Referred to
- Sai Manikanta Electrical Contractors v. Deputy Commissioner, Special Circle, Visakhapatnam [2024] 164 taxmann.com 73 (Andhra Pradesh)/[2024] 105 GST 393 (Andhra Pradesh)/[2024] 88 GSTL 303 (Andhra Pradesh) (para 3)
- Cluster Enterprises v. Deputy Asstt. Commissioner (ST)-2 [2024] 164 taxmann.com 624 (Andhra Pradesh)/[2024] 105 GST 738 (Andhra Pradesh)/[2024] 88 GSTL 179 (Andhra Pradesh) (para 3)
- Bambino Agro Industries Ltd v. State of Uttar Pradesh [2025] 181 taxmann.com 888/[2026] 105 GSTL 280 (Allahabad) (para 7)
- Sathiah Ramesh v. Deputy Commissioner (State Tax) [2026] 183 taxmann.com 149 (Madras) (para 11).
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