No DIN? RFN On GST Orders Enough To Prove Digital Signature: Andhra Pradesh High Court

The Andhra Pradesh High Court has reiterated its view that the presence of a system-generated Reference Number (RFN) on GST orders issued through the portal is sufficient to establish that the document has been digitally signed.

A Division Bench of Justice R Raghunandan Rao and Justice T.C.D. Sekhar dismissed a writ petition challenging GST assessment orders on the ground that they lacked physical signatures or a Document Identification Number (DIN).

The bench held that once an order is issued and uploaded through the GST portal and carries a system-generated Reference Number (RFN), objections based on absence of physical signatures or DIN cannot be sustained.

The petition was filed by Pedda Masthan Enterprises, which deals in ferrous scrap and re-melting scrap ingots. It questioned an assessment order dated October 28, 2023 for the period from August 2022 to February 2023, along with the related summary order issued on December 26, 2024.

The firm contended that the assessment order was invalid as it did not bear a physical or electronic signature, that the summary order lacked a Document Identification Number (DIN), and that the summary had been generated more than a year after the assessment. It also said its GST registration had been cancelled with effect from June 30, 2023 and that it was engaged in appeals relating to earlier assessment periods, which affected its ability to keep track of updates on the GST portal.

The department submitted that both the assessment order and the summary order were uploaded on the GST portal on their respective dates of issuance and that cancellation of registration did not deprive the petitioner of access to orders relating to prior tax periods.

Rejecting the DIN objection, the High Court noted that although the summary order did not separately mention a DIN, it contained a valid Reference Number generated by the system.

“The summary of the order contains Reference Number and therefore, by no stretch of imagination it can be said that the summary order does not contain Document Identification Number/Reference Number,” the bench said.

The court also noted that procedural changes in the GST portal had been demonstrated before it in earlier cases and that the absence of a separately labelled DIN could not invalidate an order carrying a unique system-generated reference number.

The High Court further held that the writ petition was barred by unexplained delay, noting that no explanation was offered for approaching the court long after the assessment and summary orders were issued.

Holding that none of the grounds raised were tenable, the Court dismissed the writ petition, with no order as to costs.

For Petitioner: Srinivasa Rao Kudupudi