GST assessment order invalidated for absence of DIN; fresh assessment permitted with notice and proper numbering.

An assessment order under the GST regime issued without a DIN number was treated as invalid because the governing CBIC circular and binding precedents consider DIN omission a defect going to the root of the proceeding. The Form GST DRC-07 order was therefore annulled. Fresh assessment was permitted, subject to issuance of notice and assignment of a DIN number, and the intervening period was directed to be excluded for limitation purposes.

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Issues: Whether an assessment order under the Goods and Services Tax regime is vitiated when it is issued without a DIN number, and what consequential relief should follow.

Analysis: The impugned Form GST DRC-07 assessment order did not contain a DIN number. The governing circular issued by the Central Board of Indirect Taxes and Customs, together with the binding precedents noticed by the Court, treats omission of a DIN number as fatal to the validity of the order. In view of that legal position, the defect went to the root of the proceeding and required the order to be annulled.

Conclusion: The assessment order was set aside, with liberty to the assessing authority to undertake fresh assessment after issuing notice and assigning a DIN number, and the relevant period was directed to be excluded for limitation purposes.

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