Unsigned GST assessment orders and missing DINs are treated as invalid, and defective service may defeat delay objections.

An assessment order issued without the assessing officer's signature was treated as a substantive defect and held invalid, with the saving provisions on irregularities not curing the defect. The text also states that a Document Identification Number is an essential requirement in GST proceedings, so an order issued without a DIN is invalid. On delay, an unsigned order was regarded as not duly served, so belated filing did not defeat the challenge. The impugned order was set aside, and fresh proceedings were permitted after due notice and proper signature.

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Issues: (i) Whether an assessment order issued without the assessing officer's signature is valid in law; (ii) whether non-mention of a Document Identification Number affects the validity of proceedings under the GST law; (iii) whether delay in approaching the Court could defeat the challenge when the unsigned order is not duly served.

Issue (i): Whether an assessment order issued without the assessing officer's signature is valid in law.

Analysis: The absence of signature on the assessment order was treated as a substantive defect. The earlier decisions relied upon held that the signature requirement cannot be dispensed with and that the saving provisions governing irregularities in notice or order do not cure such a defect. Rule 26(3) was also noted for the proposition that service of an unsigned notice or order is no service in law.

Conclusion: An assessment order issued without the assessing officer's signature is invalid.

Issue (ii): Whether non-mention of a Document Identification Number affects the validity of proceedings under the GST law.

Analysis: The judgment followed the view that a DIN is an essential requirement for the validity of GST proceedings, as reflected in the Supreme Court's ruling and the CBIC circular. Non-inclusion of the DIN was treated as a defect going to the validity of the order itself.

Conclusion: An order under the GST law without a DIN is invalid.

Issue (iii): Whether delay in approaching the Court could defeat the challenge when the unsigned order is not duly served.

Analysis: Although the writ petition was filed belatedly, the Court held that an unsigned order cannot be treated as duly served. Since there was no valid service, the delay was not treated as a decisive factor against the challenge.

Conclusion: The delay did not bar relief.

Final Conclusion: The impugned assessment order was set aside, and the assessing authority was permitted to pass a fresh order after due notice and proper signature, with the period indicated by the Court excluded for limitation purposes.

Ratio Decidendi: In GST proceedings, an unsigned assessment order and an order lacking a DIN are invalid, and an unsigned order cannot be treated as duly served for the purpose of defeating a challenge on delay.

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