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Issues: Whether a show-cause notice issued under the GST regime without a DIN number was liable to be set aside, and whether the provisional suspension of registration based on such notice could survive.
Analysis: The absence of a DIN number was treated as a material defect affecting the validity of the proceedings. Reliance was placed on the binding legal position that GST proceedings lacking a DIN are invalid, along with the CBIC circular governing DIN requirements. Since the impugned notice was uploaded in the portal but did not contain a DIN number, the notice could not be sustained. The provisional suspension was only consequential to the notice and therefore could not survive once the notice itself was invalidated.
Conclusion: The show-cause notice was set aside for want of a DIN number, and the consequential provisional suspension of registration also stood revoked. The authority was left free to proceed afresh in accordance with law after issuing notice with a DIN number.
Final Conclusion: The challenge succeeded on the ground that compliance with the DIN requirement is mandatory for the validity of GST proceedings, and the impugned action was quashed with liberty to initiate fresh proceedings lawfully.
Ratio Decidendi: Under the GST framework, a proceeding issued without the mandatory DIN requirement is invalid and cannot be sustained.