30.05.2025: Absence of a DIN in GST communications or orders violates mandatory procedural requirements – Andhra Pradesh High Court

The Andhra Pradesh High Court in the case of Monarch Industries v. State of Andhra Pradesh vide Writ Petition No. 12514 of 2025 dated 09.05.2025, has held that GST assessment orders lacking a Document Identification Number (DIN) are invalid and non-est. This decision aligns with the Supreme Court’s judgment in Pradeep Goyal v. Union of India. The Court allowed fresh proceedings with proper DIN issuance. 

Facts of the Case: In this case, the petitioner was issued a show cause notice (DRC-01) and a corresponding assessment order (DRC-07) under the CGST/APGST Act for the tax periods June 2019 and September 2019. These documents were challenged on the primary ground that they did not contain a DIN.

The Petitioner referred the CBIC Circular No. 122/41/2019-GST dated November 5, 2019, mandating the inclusion of a Document Identification Number (DIN) on all communications issued by tax authorities to ensure transparency, traceability, and accountability. Any communication without a DIN is considered invalid unless falling under specified exceptions.

Reference placed upon judgment in the case of Pradeep Goyal v. Union of India (Supreme Court) and Cluster Enterprises v. DAC and Sai Manikanta Electrical Contractors (Both Andhra Pradesh High Court) wherein upheld the validity of the DIN system and noted that documents lacking a DIN are non-est.

Held: The Court given the clear violation of CBIC circular and binding precedent from the Supreme Court. The Court held that the absence of DIN vitiates the proceedings. The orders were declared non-est and invalid. The Revenue was given liberty to re-initiate proceedings, but only after ensuring proper DIN compliance.

Register Today

Menu