Temporary GST registration and separate demand summaries enabled independent appellate remedies against a composite liability demand.

A Managing Director without GST registration was permitted to obtain a temporary identification number under Rule 16A and pursue the statutory appeal, with the limitation period to run from issuance of a fresh DRC-07. Where a composite demand fastened liability on both the company and its Managing Director, separate DRC-07 forms were required so each could challenge the demand independently. The court directed issuance of the revised forms within the stipulated time, while leaving the merits of the adjudication open.

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Issues: (i) whether the Managing Director, who had no GST registration, could be enabled to pursue the statutory appellate remedy by obtaining a temporary registration/identification number and a fresh DRC-07; (ii) whether the composite liability notice and order required separation into distinct DRC-07s for the company and its Managing Director so that each could independently challenge the demand.

Issue (i): whether the Managing Director, who had no GST registration, could be enabled to pursue the statutory appellate remedy by obtaining a temporary registration/identification number and a fresh DRC-07.

Analysis: The order records that the proper officer is empowered under Rule 16A of the Central Goods and Services Tax (Amendment) Rules, 2025 to grant a temporary identification number and issue an order in Part B of Form GST REG-12. On that basis, the Managing Director was held entitled to apply for a temporary registration/identification number so that he could avail the appellate remedy and raise all factual and legal grounds available to him. The Court also directed that the limitation for appeal would run only from the issuance of the fresh DRC-07.

Conclusion: The issue was answered in favour of the petitioner Managing Director.

Issue (ii): whether the composite liability notice and order required separation into distinct DRC-07s for the company and its Managing Director so that each could independently challenge the demand.

Analysis: The impugned adjudication had fastened liabilities in a composite manner on both the company and its Managing Director. The Court accepted that separate DRC-07 forms were necessary, one for the company and one for the Managing Director, to enable each aggrieved person to prefer a separate appeal. Directions were issued for issuance of the revised forms within a fixed time frame, while leaving the merits of the challenge open.

Conclusion: The issue was answered in favour of the petitioners.

Final Conclusion: The writ petitions were disposed of with directions securing the petitioners' appellate remedy, including temporary registration for the Managing Director and issuance of separate demand summaries, while the merits of the adjudication were left untouched.

Ratio Decidendi: Where a composite GST demand affects persons who require separate appellate standing, the authority must facilitate independent appellate access through separate demand summaries and, where necessary, temporary registration or identification so that limitation runs from the fresh demand summary.

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