HC Holds GST Assessment Order Without DIN or RFN Invalid

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.