Writ Petition Dismissed as Court Emphasizes RFN Sufficiency Over DIN in GST Communications
In a significant ruling, the Rajasthan High Court dismissed a writ petition challenging the validity of GST orders due to the absence of a Document Identification Number (DIN). The Division Bench, comprising Justices Arun Monga and Sunil Beniwal, delivered the judgment on April 10, 2026, in the case of Shri Mahesh Trivedi v. Union of India. The petitioner contended that the GST order imposing penalties for wrongful availing and fraudulent passing of Input Tax Credit (ITC) lacked a DIN, thereby rendering it void.
The petitioner, Shri Mahesh Trivedi, argued that the absence of a DIN, as mandated by Circulars No. 122/41/2019-GST and No. 128/47/2019-GST, made the order non-existent in the eyes of the law. The counsel for Trivedi emphasized that exceptions to this requirement necessitate written reasons and declarations within the communication, neither of which were present.
However, the respondents countered that the order prominently displayed a Reference Number (RFN), "I/3740446/2025," which is traceable and verifiable via the GST portal. This RFN fulfills the purpose of authenticity and verification akin to a DIN, according to the court's analysis. The court noted that the RFN is a unique identifier that links the communication electronically, thus meeting legal requirements.
The bench referred to Section 169 of the Central Goods and Services Tax Act, 2017, which outlines valid service methods for GST communications, including electronic uploads, registered post, and email. The court highlighted that the impugned order was indeed uploaded on the GST portal and dispatched via registered post and email, satisfying lawful communication criteria.
Further, the court examined a CBIC circular dated June 9, 2025, which modified previous circulars by clarifying that communications bearing a verifiable RFN do not require a separate DIN. This circular was pivotal in the court's decision, affirming that RFNs serve the same purpose as DINs, thereby validating the communication.
Concluding the judgment, the court dismissed the writ petition, underscoring that the challenge based solely on the absence of a DIN was unsubstantial. However, the court allowed the petitioner the opportunity to pursue an appellate remedy, excluding the period spent in the writ petition from the limitation calculation.
This judgment reinforces the legal standing of GST communications with RFNs, streamlining processes and ensuring clarity in administrative procedures.
Bottom line:-
Absence of Document Identification Number (DIN) in GST communications does not render them invalid if they bear a verifiable Reference Number (RFN) generated through the GST common portal, which serves the purpose of traceability, authenticity, and verification.
Statutory provision(s): Central Goods and Services Tax Act, 2017 Section 169, CBIC Circulars
Shri Mahesh Trivedi v. Union of India, (Rajasthan)(DB) : Law Finder Doc id # 2894551
