HC Rules Assessment Order Without DIN Invalid but Effective Until Set Aside

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  • Last Updated on 3 October, 2025

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GST Assessment Orders without DIN

Case Details: Mahadev Transport and Contractors vs. Assistant Commissioner - [2025] 177 taxmann.com 858 (Andhra Pradesh)

Judiciary and Counsel Details

  • R Raghunandan Rao & SMT. Sumathi Jagadam, JJ.
  • Karthik Ramana Puttamreddy & Srinivasa Rao Kudupudi for the Petitioner

Facts of the Case

The petitioners, registered under the GST regime, challenged assessment orders on the ground that the orders did not bear a Document Identification Number (DIN). They relied on ‘Circular No. 122/41/2019-GST, dated: 05-11-2019’, which mandates electronic generation of DIN for all communications under the CGST Act/Rules, and ‘Circular No. 128/47/2019-GST, dated: 23-12-2019’ which provides that specified communications issued without an electronically generated DIN would be treated as invalid and deemed never to have been issued. The petitioners contended that the absence of DIN rendered the assessment orders invalid and requested that the orders be set aside. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that instructions issued by the CBIC under Section 168 are binding on taxation authorities, and violation of such instructions may constitute a procedural irregularity. However, the Court observed that such a violation alone does not render the assessment orders void. Consequently, the assessment orders under challenge continue to remain effective unless set aside by the Court.

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