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.

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.