GST assessment orders without a DIN were invalid, and the consequential bank attachment was also set aside.

GST assessment orders issued without a dynamic identification number were held invalid because DIN was treated as a mandatory feature ensuring authenticity and traceability of communications. The orders were therefore quashed for want of DIN. The bank attachment, being wholly consequential to those assessment orders, could not survive once the foundation of recovery disappeared, and it was also set aside. Fresh assessment was left open in accordance with law, with the intervening period excluded for limitation purposes.

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Issues: (i) Whether assessment orders under the Goods and Services Tax regime are valid when they do not contain a dynamic identification number (DIN); (ii) whether the bank attachment arising from such assessment orders can survive once the orders are set aside.

Issue (i): Whether assessment orders under the Goods and Services Tax regime are valid when they do not contain a dynamic identification number (DIN).

Analysis: The assessment orders were admittedly issued without a DIN. The controlling circular and the earlier decisions referred to in the order treated DIN as a mandatory feature intended to ensure authenticity and traceability of GST communications. On that basis, non-mention of DIN was held to affect the validity of the proceedings.

Conclusion: The assessment orders without DIN were invalid and liable to be set aside.

Issue (ii): Whether the bank attachment arising from such assessment orders can survive once the orders are set aside.

Analysis: The attachment was consequential to the impugned assessment orders. Once the assessment orders were annulled, the foundation for recovery by attachment also ceased to exist. The order also preserved the authority to undertake fresh assessment after notice and assignment of DIN, and directed exclusion of the intervening period for limitation purposes.

Conclusion: The bank attachment could not survive and was also set aside.

Final Conclusion: The impugned GST assessment orders were quashed for want of DIN, consequential recovery attachment was nullified, and the matter was left open for fresh assessment in accordance with law.

Ratio Decidendi: A GST assessment order issued without a DIN is invalid, and any consequential recovery action based solely on such order cannot stand.

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