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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.

Document Identification Number requirements in GST communications and search authorisations, including reasons to believe and RFN applicability. Questions arise on whether DIN requirements under GST circulars extend to officer-to-officer communications, including search approval by a higher authority, and whether reasons to believe recorded in e-file or e-office must carry RFN or issue number. The queries also ask whether the applicable identifier depends on the date of the search and whether DIN, RFN, or issue number is mandatory when recording reasons to believe for search and seizure, so as to prevent later alteration by a higher officer. (AI Summary)
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