GST assessment without DIN is invalid; non-mention of DIN can render the proceeding liable to be quashed.

An assessment order under the GST framework issued without a DIN was treated as invalid because GST communications and orders are required to bear a DIN under the applicable CBIC circular. The Court followed the settled position that absence of a DIN goes to the validity of the proceeding, and the impugned assessment was set aside. The authority was permitted to proceed afresh after issuing notice and assigning a DIN, with time spent in the earlier proceeding excluded for limitation purposes.

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Issues: Whether an assessment order under the GST regime is liable to be set aside for want of a DIN number.

Analysis: The order challenged before the Court did not contain a DIN number. Reliance was placed on the settled position that GST communications and orders must bear a DIN in terms of the applicable CBIC circular, and that absence of DIN affects the validity of the proceeding. The Court followed the earlier legal position treating non-mention of DIN as fatal to such proceedings.

Conclusion: The impugned assessment order was held invalid and was set aside.

Final Conclusion: The writ petition succeeded, the assessment was annulled, and the assessing authority was permitted to proceed afresh after issuing notice and assigning a DIN, with consequential exclusion of time for limitation.

Ratio Decidendi: An assessment or tax order under the GST framework that is issued without a DIN number is invalid and liable to be quashed.

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