Is DIN for Officer to Officer communication, mandatory i.e. for search approval by Higher authority to lower authority also or for recording reasons to believe DIN is mandatory

[HimangshuKumar Ray]

Dear Sir(s) / Mam(s),

I have a query. CBIC issued DIN circular on 05.11.2019, 23.12.2019, 09.06.2025 and last modified some extent on 23.09.2025. In those circulars the language used... ' .... to Tax payers and other concerned persons'.. DIN is mandatory and later RFN and later issue number in e-office application is mandatory and other communication DIN is mandatory.

My first query -- 'concern person' meaning thereby officer to officer, like one High officer approving search authorisation to lower officer, where DIN is mandatory.

my 2nd query -- When reasons to believe records in the e-file / e-office, then as per circular dt. 23.09.2025, should be followed by the recording officer by RFN or issue number.

my 3rd query - if search before 23.09.2025- where higher officer records 'reasons to believe' for search, is there DIN is mandatory or RFN number is mandatory as per circular dt. 09.06.2025, if search took place after 09.06.2025.

my 4th query - Whether while recording reasons to believe for search, seizure, under GST Act, DIN or RFN / Issue number, as applicable, mandatory, otherwise if not mandatory, then there is a possibility to change the reasons to believe any time by the High officer.

I am waiting for yours kind guidance.

With regards.

[YAGAY andSUN]

1. Scope of "taxpayers, other concerned persons"

The expression "taxpayers and other concerned persons" in DIN circulars is intended to cover communications issued by the Department to persons outside the Department. It includes taxpayers, third parties, and external stakeholders who receive notices, orders, or communications having legal consequences.

It does not extend to internal departmental processes, inter-officer approvals, or file noting. Accordingly, internal actions such as approval of "reasons to believe" for search or seizure are outside the scope of DIN requirements.

DIN is therefore confined to externally issued communications and not internal record-making or decision recording.

2. "Reasons to believe" recorded in e-Office (post 23.09.2025)

"Reasons to believe" under Section 67 of the CGST Act is an internal statutory satisfaction recorded by the competent authority in the departmental file. It is not a communication issued to taxpayers.

As per the e-Office integration framework (Circular dtd 23.09.2025), such internal records are required to be maintained with RFN (Record/File No) or e-Office Issue Number.

DIN is not applicable, as:

• the record is internal in nature, and
• not issued outside the Department.

3. Search after 09.06.2025 and applicability of DIN/RFN

The applicability of DIN or RFN depends on the date of recording of the document, not the date of search.

Accordingly:

• If "reasons to believe" is recorded after e-Office integration (post 09.06.2025 / 23.09.2025 framework), RFN/Issue Number applies.
• If recorded earlier, the pre-existing DIN regime or manual system applies, depending on issuance context.

The date of search does not determine the compliance requirement of the underlying recorded satisfaction.

4. Mandatory nature & alteration of records

DIN is mandatory only for external communications issued to taxpayers or concerned persons outside the Department. RFN/e-Office Issue Number is mandatory for internal statutory records, including "reasons to believe".

Once recorded in the e-Office system:

• the document is time-stamped,
• digitally traceable, and
• subject to audit trail & version control.

So, any modification is not permitted in a unilateral or untraceable manner, any change necessarily generates a system-recorded history. This ensures integrity of the record and prevents post facto alteration.

[Sadanand Bulbule]

Here I wish to add:

Under the provisions of Section 69 of the CGST Act, the copy of the "reasons to believe" must be given to the person likely to be arrested. On the same score, under Section 67 too, the person likely to be inspected shall also be given copy of the "reasons to believe". Internal satisfaction is not enough to conduct inspection as every authority would have his own reasons, much less justifiable. Taxpayers have every right to ask or question this. Law is well settled on this issue.

[KASTURI SETHI]

The phrase, "other concerned persons" inter alia, implies co-noticees.

AI Summary

DIN requirements for GST communications do not extend to internal reasons to believe recorded in e-Office. DIN circulars are discussed as applying to communications issued outside the Department, including notices, orders and other communications to taxpayers and other concerned persons, while internal officer-to-officer approvals, file notings and similar departmental processing are treated as outside the DIN requirement. The discussion further states that reasons to believe for search or seizure under GST are internal statutory satisfaction and, where recorded in e-Office, should bear RFN or an e-office issue number rather than DIN.