DIN-free assessment orders, portal service, and delayed writ relief were balanced through conditional remand and partial tax deposit.

An assessment order issued without a Document Identification Number was treated as suffering from an inherent defect, exposing it to judicial interference. The Court also considered whether portal upload amounted to valid service under Section 169(1)(d) of the CGST Act and noted practical difficulties faced by registered persons in accessing portal-based communications. Balancing taxpayer hardship and revenue protection, the Court granted conditional relief despite delay in approaching the Court, set aside the assessment, and remanded the matter for fresh adjudication after due opportunity of hearing, subject to deposit of part of the disputed tax.

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Issues: Whether an assessment order lacking a Document Identification Number was liable to be set aside; whether service of the order by uploading it in the portal constituted valid service; and whether the writ petition deserved relief despite delay in approaching the Court.

Analysis: The order of assessment was found to suffer from the absence of a DIN, which was treated as an inherent defect warranting interference. On the question of service, the Court noticed the contention that portal upload amounted to service under Section 169(1)(d) of the Central Goods and Services Tax Act, 2017, but balanced the practical difficulties faced by registered persons in accessing portal-based communications. In the circumstances, the Court considered it appropriate to grant relief while protecting the revenue by directing deposit of a portion of the disputed tax.

Conclusion: The assessment order was set aside and the matter was remanded to the Assessing Officer for fresh adjudication after due opportunity of hearing, subject to deposit of 20% of the disputed tax within six weeks.

Final Conclusion: The writ petition was disposed of by granting conditional relief to the petitioner, with the assessment reopened for reconsideration on merits.

Ratio Decidendi: An assessment order vitiated by absence of DIN can be interfered with, and where portal-based service and delay are in issue, conditional relief by way of remand and partial deposit may be granted to balance taxpayer hardship and revenue interests.

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