GST assessment order quashed as absence of Document Identification Number (DIN) rendered it invalid under CBIC circular and Supreme Court precedent

Case Summary: M/s Granite v. Deputy Assistant Commissioner & Others, Andhra Pradesh High Court, W.P. No. 8734 of 2025, decided on 02.04.2025
Category: Validity of Assessment Order – DIN Non-mention
Relevant Sections: Section 73 / 74 of the CGST Act 2017; CBIC Circular No. 128/47/2019-GST dated 23.12.2019

Facts (Para 1–3)

The petitioner, M/s Granite, was served with an assessment order dated 01.08.2024 under the GST Act for FY 2017-2022, issued in Form GST DRC-07 by the Deputy Assistant Commissioner. The order was challenged primarily on the ground that it did not bear a Document Identification Number (DIN), in violation of CBIC’s circular mandating DIN for all communications to ensure transparency and audit trail. The State’s counsel conceded that the impugned order indeed lacked a DIN reference.

Questions before the Court (Para 3–4)

Whether an assessment order issued under the GST Act without a DIN is valid and enforceable in light of the CBIC Circular No. 128/47/2019-GST and the Supreme Court’s decision in Pradeep Goyal v. Union of India (2022 (63) G.S.T.L. 286 (SC)).

Observations (Para 4–6)

The Bench noted that the Supreme Court in Pradeep Goyal v. Union of India had unequivocally held that a communication issued without DIN is “non-est and invalid.”
Further, the Division Bench of the Andhra Pradesh High Court in M/s Cluster Enterprises v. Deputy Assistant Commissioner (ST)-2, Kadapa (2024 (88) G.S.T.L. 179 (AP)) and in Sai Manikanta Electrical Contractors v. Deputy Commissioner (ST), Visakhapatnam (2024 (88) G.S.T.L. 303 (AP)) had also invalidated orders for lack of DIN.
The Court reiterated that DIN is mandatory for every communication and its absence vitiates the order, irrespective of the merits of the assessment.

Judgment (Para 6–7)

The Court quashed the assessment order dated 01.08.2024 for non-mention of DIN and directed the authority to pass a fresh order after issuing proper notice and assigning a valid DIN.
The interim period—from the date of the impugned order till receipt of this judgment—was excluded for limitation purposes.
No order as to costs was made.

Table – Precedents Referred and Their Verdicts

Between Fine Lines – Practical Takeaway

Every communication, order, or notice under GST must bear a DIN to maintain transparency and accountability. Tax officers cannot issue manual or non-DIN orders even if uploaded on the portal. Businesses should verify DIN before accepting the authenticity of any communication. Absence of DIN renders the document void ab initio and challengeable in writ jurisdiction.

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