GST assessment invalid for missing Document Identification Number; delayed writ challenge allowed with protective deposit and remand.

An assessment order under the GST regime was treated as invalid because it lacked a Document Identification Number, the defect being regarded as inherent and vitiating the order. The High Court also recognised practical difficulties in accessing portal-based GST communications and allowed delayed writ challenges to be entertained on equitable terms, subject to deposit of 20% of the disputed tax. The impugned order was quashed and the matter remanded for fresh adjudication after due opportunity of hearing.

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Issues: Whether the assessment order was liable to be set aside for want of a Document Identification Number, and whether delayed writ challenges to GST orders could be entertained with a condition of deposit of part of the disputed tax.

Analysis: The order under challenge was found to suffer from the absence of a Document Identification Number, which was treated as an inherent defect vitiating the assessment. The Court also noted the practical difficulties faced by registered persons in accessing portal-based communications under the GST regime, and balanced those difficulties against the revenue interest by permitting delayed writ petitions to be considered subject to payment of 20% of the disputed tax. The impugned order was therefore quashed and the matter was sent back for fresh consideration after giving the petitioner due opportunity of hearing.

Conclusion: The assessment order was set aside and the matter was remanded to the Assessing Officer for fresh adjudication, with the petitioner required to deposit 20% of the disputed tax within six weeks.

Ratio Decidendi: An assessment order under the GST regime that suffers from the absence of a Document Identification Number is liable to be invalidated, and delayed writ relief may be entertained subject to a protective deposit where equitable balancing of interests is warranted.

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