TaxTMI 
TaxTMI 
2026 (2) TMI 508
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....notice of attachment in Form GST DRC-16, dt.19.12.2025 issued by the 3rd respondent as illegal, on the ground that the assessment order does not contain DIN and the notices issued prior to the passing of assessment order do not contain signature. 2. The petitioner is a registered dealer under Goods and Service Tax Act, 2017 and it engaged in the business of supply of manpower services to APSRTC. It is further case of the petitioner that, the 3rd respondent having noticed the discrepancies in the returns filed by the petitioner, issued preshow cause notice in Form DRC-01A, dt. 22.12.2023 in relation to period 2019-2020. Thereafter, the 3rd respondent issued show cause notice in Form DRC-01, dt. 02.12.2023 proposing to levy tax, penalty an....
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....ssed in the year 2024 and the petitioner did not explain the delay either in filing the appeal before the 2nd respondent or approaching this Court by filing the present writ petition. He would further submit that, all the show cause notices and the assessment order were uploaded in the portal on the date of issuance of the same. In such an event, the petitioner cannot contend that it had no proper knowledge to verify the same through portal. 8. It is not in dispute that the assessment order was passed on 12.06.2024 and the same was uploaded in the portal on the same day. The contention of the petitioner that he had no proper knowledge in verifying the portal cannot be accepted inasmuch as on perusal of the averments made in the affidavit....
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....ar that the same does contain Reference No: 37AAQFK8683D17Q/2019-20/DRC-07. It is pertinent to note this reference number is auto generated by the system while uploading the order of assessment in the portal. Further, this number is exclusively assigned to the assessment order in question. 10. Further, this Court while dealing with the similar issues, rejected the same by order dt.26.09.2025 held as under: "13. This Court, which is being confronted, by various models of signatures being affixed on the proceedings of the tax authorities, with a view to understand the significance of these signatures and whether what is printed on the orders or notices indicate affixture of the digital signatures had sought the assistance of Smt. ....
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.... W.P.No.1363 of 2026 by order dt.31.01.2026, which is as under: "12. The other ground raised by the petitioner that, summary order does not contain DIN is concerned, on perusal of summary of the order though it does not contain DIN, but on a close perusal of the same, it is evident that summary order does contain Reference Number: ZD3712240385479 (RFN). This reference number would be generated after the assessing authority affixes signatures on the order. Further, the GST portal underwent several procedural changes in uploading the orders. As noted supra, the officials of Central GST Department demonstrated the manner in which the signatures and DIN/Reference Number would be assigned to the orders, which are uploaded in the portal.....