DIN Absence in Assessment Order Not Fatal; GST Portal-Generated RFN Validates Digital Authentication: Andhra Pradesh High Court

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The Andhra Pradesh High Court has reaffirmed the legal validity of electronically issued GST orders, holding that the absence of a physically printed Document Identification Number (DIN) on an assessment order does not render it invalid when the order is digitally authenticated through the GST portal. In [2026] 183 taxmann.com 604 (Andhra Pradesh), the Court ruled that a Reference Filing Number (RFN) generated during portal uploading constitutes valid digital authentication and satisfies statutory requirements.

The judgment underscores the shift from paper-based procedural formalities to a fully digital compliance regime under GST and clarifies that electronically issued show-cause notices and summary assessment orders cannot be invalidated merely due to non-mention of DIN on the face of the document, so long as the system-generated authentication trail exists.

Case Name & Citation

  • Case Title: M/s. Pedda Masthan Enterprises v. Assistant Commissioner ST (reported as 2026 LLBiz HC(APHC) 14 / [2026] 183 taxmann.com 604)
  • Court: High Court of Andhra Pradesh at Amaravati
  • Bench: R. Raghunandan Rao & T.C.D. Sekhar, JJ.
  • Decision Date: January/February 2026 (reported in Feb 2026)

Background & Facts

  • The petitioner, Pedda Masthan Enterprises, was subject to GST assessment for the period Aug 2022 to Feb 2023.
  • The GST department issued:
    • A show-cause notice (Form DRC-01),
    • An assessment order (DRC-07) dated 28.10.2023, and
    • A summary assessment order (DRC-07) dated 26.12.2024, all via the GST portal.
  • The petitioner argued that:
    1. Both orders lacked a physical signature of the officer;
    2. The summary order did not bear a DIN (Document Identification Number) as required by earlier procedural norms; and
    3. The challenge to the order was filed after significant delay, partly due to GST registration cancellation.

Legal Issues Raised

The petitioner contended that:

  1. Absence of Physical/Digital Signature and
  2. Absence of a DIN on the summary order

rendered the GST orders invalid/void in law and unenforceable.

High Court’s Findings & Judgment

✔️ 1. Digital Sign + RFN Sufficient

  • The Court held that orders issued via the GST Common Portal, which automatically generate a Reference Filing Number (RFN) upon affixture of a digital signature, are legally valid.
  • The RFN itself serves as proof of digital authentication, making separate physical signatures or a stand-alone DIN unnecessary for procedural validity.
  • A system-generated RFN conclusively indicates the order was digitally signed and authenticated in law.

Takeaway:
🟢 Absence of a manually printed DIN or signature is not a fatal flaw where the portal has supplied an RFN.

✔️ 2. DIN Not Mandatory in Portal-Issued Orders

  • The absence of a separately mentioned Document Identification Number (DIN) on the summary order did not invalidate the order, because:
    • The RFN generated by the portal functions as the unique identifier (akin to a DIN) and
    • Portal-based electronic compliance is now the operative regime.

✔️ 3. Doctrine of Laches — Delay in Filing

  • The court also dismissed the writ petition on grounds of delay and laches, noting the petitioner failed to give any credible explanation for approaching the court long after the orders were uploaded on the portal.
  • Access to the GST portal remains even after registration cancellation, so lack of notice due to cancellation could not justify delay.

Key Legal Principles Affirmed

  1. Digital Authentication over Paper Formalities:
    Portal-generated RFN/digital signatures satisfy statutory and procedural requirements — physical DIN or signature on printed copies is no longer essential for validity.
  2. Portal Service Is Valid:
    Uploading orders on the GST portal constitutes valid service, and the taxpayer cannot claim ignorance if the portal access was available.
  3. Delay Matters:
    A writ petition is liable to be dismissed if filed after an unreasonable delay without explanation, especially where orders were available on the portal.

Practical Implications for Tax Litigation

  • Challenges based on missing DIN in electronic orders will likely fail if RFN is generated.
  • Tax authorities can safely rely on electronic signatures and portal mechanisms.
  • Taxpayers must monitor portal uploads and act promptly (appeal or writ) within limitation periods.
  • The judgment reinforces the evolution from paper-centric DIN requirements to a digital compliance framework in GST proceedings.
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