Facts of the Case:

In this case, the petitioner challenged the assessment order and the consequential attachment notice in Form GST DRC-16 issued under Section 79 of the GST Act. The assessment proceedings were initiated after discrepancies were noticed in the petitioner’s returns for the tax period 2019–2020. A pre-show cause notice in Form DRC-01A and a show cause notice in Form DRC-01 were issued proposing levy of tax, interest, and penalty. The petitioner did not file objections to the show cause notice and an assessment order was passed on 12.06.2024, which was uploaded on the GST portal on the same day. An appeal filed by the petitioner was rejected on 16.07.2025.

The petitioner contended that the assessment order was invalid as it did not contain a Document Identification Number (DIN) as required under Circular No. 122/41/2019-GST dated 05.11.2019, and further that the pre-show cause notice and show cause notice were unsigned and therefore non-est in law.

Issue:

Whether the assessment order was invalid for not containing a DIN, whether the show cause notices were invalid for want of signature. 

Held that:

The Court held that such RFN is auto-generated upon digital signing of the order and is exclusively assigned to the particular proceeding. Relying on earlier decisions, the Court observed that GST notices and orders issued electronically cannot be generated unless digitally signed by the competent authority. The presence of an RFN sufficiently establishes digital authentication, and therefore, the contention regarding absence of DIN or signature was untenable.

The Court further noted that the petitioner was aware of the assessment proceedings, as it had earlier responded to notices in Form GST ASMT-10. The plea that the petitioner had no knowledge of portal communications was rejected. Additionally, the petitioner failed to satisfactorily explain the delay in filing the appeal as well as the delay in approaching the High Court after rejection of the appeal. In the absence of a valid explanation for such delay, the writ petition was liable to be dismissed on the ground of laches.

The Court dismissed the writ petition holding that there was no merit in the contentions raised by the petitioner. It was observed that the assessment order was uploaded on the GST portal on the date of its issuance and carried a system-generated Reference Number (RFN).

Case Name: Kudos Facililty Services Versus The State Of Andhra Pradesh, The Additional Commissioner ST, Appellate Authority, Vijayawada., The Deputy Assistant Commissioner St, Eluru-LL Circle, The Assistant Commissioner St, Eluru. dated 09.02.2026