GST orders lacking a Document Identification Number were treated as invalid, with remand ordered subject to a tax deposit condition.

GST assessment orders without a Document Identification Number were treated as inherently defective and liable to be invalidated. The Court also indicated that, despite delay and disputed service through the GST portal, writ relief may be considered where a patent irregularity exists, with the dispute remitted for fresh adjudication after hearing. In balancing taxpayer hardship and revenue protection, the matter was sent back to the assessing authority with a condition to deposit 20% of the disputed tax within six weeks.

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Issues: (i) Whether assessment orders issued under GST without a Document Identification Number were vitiated. (ii) Whether the writ petition could be entertained despite delay and whether the matter should be remanded on a conditional deposit basis.

Issue (i): Whether assessment orders issued under GST without a Document Identification Number were vitiated.

Analysis: The orders under challenge did not bear a DIN or RFN number. The Court treated the absence of a DIN as an inherent defect in the assessment orders and referred to its earlier view that such absence is sufficient to invalidate the orders.

Conclusion: Yes. The impugned assessment orders were held to be vitiated for want of DIN.

Issue (ii): Whether the writ petition could be entertained despite delay and whether the matter should be remanded on a conditional deposit basis.

Analysis: The Court noted the dispute over service through the GST portal and the delay in approaching the Court, but balanced the hardship faced by registered persons against the need to protect revenue administration. It held that writ petitions in such circumstances can be considered subject to deposit of a portion of the disputed tax and that the impugned orders should be set aside with a fresh opportunity of hearing before the assessing authority.

Conclusion: Yes. The matter was remanded to the Assessing Officer with a condition to deposit 20% of the disputed tax within six weeks.

Final Conclusion: The assessment orders were set aside for the absence of DIN and the dispute was sent back for fresh adjudication after opportunity of hearing, with interim protection to the assessee and a conditional tax deposit requirement.

Ratio Decidendi: An assessment order under GST that is not duly identified by a DIN is liable to be invalidated, and where such patent irregularity exists, the Court may grant limited writ relief and remit the matter for fresh consideration while balancing revenue interests through a deposit condition.

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