Document Identification Number defects can invalidate assessment orders, with remand allowed subject to partial tax deposit.

Assessment orders issued without a Document Identification Number were treated as vitiated by an inherent defect, and the Court set them aside. Balancing the defect against revenue protection and GST administration, the matter was remanded to the assessing authority for fresh orders after granting due opportunity of hearing. The challenge was entertained on a condition that the petitioner deposit part of the disputed tax, reflecting the Court's approach of allowing reconsideration while safeguarding the revenue interest.

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Issues: Whether assessment orders lacking a Document Identification Number were liable to be set aside, and whether the assessment should be remanded with a condition of deposit of part of the disputed tax.

Analysis: The absence of a DIN was treated as an inherent defect in the impugned assessment orders. The Court followed its earlier view that such defect vitiates the orders, while also balancing the practical difficulties arising in GST administration and the need to protect the revenue interest. In that context, the Court held that delay-linked challenges of this kind could be entertained on the condition of depositing 20% of the disputed tax, and that the matter should go back to the assessing authority for fresh orders after giving due opportunity of hearing.

Conclusion: The assessment orders were set aside and the matter was remanded to the Assessing Officer, subject to the petitioner depositing 20% of the disputed tax within six weeks.

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