Document Identification Number defect vitiates GST assessment order, while portal upload alone may not defeat delayed challenge.

An assessment order issued without a Document Identification Number was treated as suffering from an inherent procedural defect and was set aside, with the matter remanded for fresh adjudication after hearing. On service, portal uploading under the GST regime was considered under section 169(1)(d), but was not treated as a complete answer to defeat relief where the order itself was procedurally defective. The writ challenge was entertained despite the delay issue, subject to a 20% pre-deposit of the disputed tax as interim fiscal protection.

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Issues: (i) Whether an assessment order issued without a Document Identification Number was liable to be set aside; (ii) whether uploading the order in the GST portal constituted sufficient service so as to defeat the challenge on delay.

Issue (i): Whether an assessment order issued without a Document Identification Number was liable to be set aside

Analysis: The absence of a Document Identification Number was treated as an inherent defect in the assessment order. The Court followed its earlier view that such absence vitiates the order, and considered the defect serious enough to warrant interference despite the dispute regarding delay.

Conclusion: The assessment order was set aside and the matter was remanded to the Assessing Officer.

Issue (ii): Whether uploading the order in the GST portal constituted sufficient service so as to defeat the challenge on delay

Analysis: Section 169(1)(d) of the Central Goods and Services Tax Act, 2017 was relied upon for service through the portal, but the Court noticed the competing view that such uploading may not amount to effective service in all cases. Balancing the practical difficulties faced by registered persons with the need for tax administration, the Court permitted delayed challenges to be considered on payment of part of the disputed tax.

Conclusion: Uploading in the portal was not accepted as a complete answer to defeat relief, and the writ petition was entertained subject to deposit of 20% of the disputed tax.

Final Conclusion: The assessment order was interfered with for want of a Document Identification Number, the matter was sent back for fresh adjudication after hearing, and interim fiscal protection was imposed through a partial pre-deposit requirement.

Ratio Decidendi: An assessment order lacking a Document Identification Number is vitiated, and portal-upload service under the GST regime does not, by itself, bar relief where the order suffers from a patent procedural defect.

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