The Andhra Pradesh High Court upheld orders involving Kudos Facility Services, saying DIN absence does not invalidate electronically issued documents reference numbers. Justices Rao Raghunandan Rao and T. C. D. Sekhar held digital validity and compliance were adequately proven.
ANDHRA PRADESH: The Andhra Pradesh High Court has upheld a goods and services tax (GST) assessment order against Kudos Facility Services, determining that the absence of a Document Identification Number (DIN) on the physical copy does not nullify an electronically issued order from the tax department if it includes a system-generated reference number.
A division bench comprising Justices Rao Raghunandan Rao and T. C. D. Sekhar stated that the reference number generated on the GST portal is adequate to prove that the order was digitally authenticated.
This case pertains to a GST dispute from the 2019–20 fiscal year. The tax department initiated proceedings after identifying discrepancies in the company’s returns and later issued the assessment order when no response was received.
The petitioner contended that the order was invalid due to the lack of a DIN, as mandated by a 2019 GST circular, and argued that the notices were not properly signed. However, the court dismissed this argument, asserting that the portal-based digital system provides sufficient authentication on its own.
The DIN requirement was established through a 2019 GST circular to enhance traceability and accountability in departmental communications. However, tax experts noted that the subsequent shift towards portal-based authentication demonstrates the government’s increasing reliance on the inherent digital safeguards within the GST system.
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This ruling coincides with the recent insertion of Section 292BA in the Income Tax Act as part of Budget 2026, which retroactively validates direct tax orders issued from October 2019, despite any DIN-related issues, as long as the DIN was properly generated.
Ikesh Nagpal, remarked that the DIN requirement has evolved in “layers.”
He explained,
“The 2019 circular introduced DIN as a mandatory safeguard to enhance transparency and traceability in tax communications. The subsequent 2025 circular diluted that requirement in the GST context, recognising the robustness of portal-based digital authentication.”
With this judgment affirming the adequacy of system-generated reference numbers (RFNs) and digital signatures, the legal stance appears settled at least for the future, Nagpal observed.
He added,
“However, the regulatory journey may not feel straightforward. When a safeguard is initially made compulsory and later relaxed, it naturally raises questions about consistency and expectations. The court’s ruling does signal a broader shift and provides significant clarity regarding the statutory digital framework’s ability to ensure authenticity and traceability; procedural form should not overshadow substantive compliance,”
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