GST assessment order without mandatory DIN is legally invalid, and a direct writ challenge remains maintainable despite a time-barred appeal.

An assessment order issued under the GST framework without the mandatory Document Identification Number is treated as legally invalid and non-est, so it cannot stand in law. A direct writ challenge to that foundational order remains maintainable even where the statutory appeal was rejected as time-barred, because limitation on the appeal does not cure or validate the underlying illegality. The assessment order was set aside and the matter remanded for fresh adjudication in accordance with law.

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Issues: (i) Whether an assessment order under the GST regime, which does not contain a Document Identification Number, is valid in law. (ii) Whether a challenge to the original assessment order is maintainable after the statutory appeal against that order has been rejected as time-barred.

Issue (i): Whether an assessment order under the GST regime, which does not contain a Document Identification Number, is valid in law.

Analysis: The decision proceeds on the basis that the absence of a DIN renders the order non-compliant with the governing GST framework as understood in the binding precedent referred to in the order. An order issued without the required DIN is treated as lacking legal validity and as non-est.

Conclusion: The assessment order without a DIN is invalid and non-est.

Issue (ii): Whether a challenge to the original assessment order is maintainable after the statutory appeal against that order has been rejected as time-barred.

Analysis: The order relies on the view that rejection of the appeal on limitation does not bar a direct challenge to the original assessment order where the challenge concerns the legality of that order itself. The pendency or disposal of the appeal does not extinguish the right to question the foundational assessment in such circumstances.

Conclusion: The writ challenge to the original assessment order is maintainable notwithstanding rejection of the appeal on limitation.

Final Conclusion: The assessment order was set aside and the matter was remanded to the Assessing Officer for fresh adjudication in accordance with law, with consequential relief on limitation.

Ratio Decidendi: An assessment order issued under the GST framework without the mandatory DIN is legally invalid, and such invalidity can be challenged directly even after a time-barred appeal against that order has been rejected.

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