The Madras High Court has held that the presence of a Document Identification Number (DIN) on an appellate order does not, by itself, establish that the order was served on the assessee. The court ruled that the DIN cannot be used to establish the date of service for calculating the limitation period for an appeal.

A Division Bench of Justice Anita Sumanth and Justice S. Raveekumar was dealing with a batch of nine appeals filed by Greaves Cotton Ltd. challenging CESTAT orders dismissing its Service Tax appeals as barred by limitation.

The dispute concerned the date on which the first appellate orders were served. Greaves Cotton received copies of the orders on March 31, 2025 and filed its appeals before CESTAT on June 3, 2025.

The taxpayer company treated March 31 as the date of service and contended that the appeals were within time.

The Revenue argued that the DIN on the appellate orders showed that they had been uploaded on the portal. It contended that the assessee should have obtained the orders from the portal instead of waiting for postal service.

The court rejected the Revenue's reliance on the DIN, observing:

“The fact that a DIN features in the appellate order means nothing than an authentication of the order, and we cannot infer anything about service of the order from this, as Mr.Raghavan would ask us to.”

The court noted that the Revenue had not produced evidence that the order was uploaded or served electronically. A DIN, by itself, could not establish service.

It also referred to Section 37C of the Customs Act, which requires orders to be served by registered post or speed post with acknowledgement due. An RTI response showed that the order was sent by speed post, but there was no record of an acknowledgement.

The court therefore treated March 31, 2025, when the assessee received the order, as the date of service. It held that the appeals filed before CESTAT on June 3, 2025 were within time and quashed the tribunal's orders.

The court also held that the first appeals filed on May 30, 2022 were maintainable, as the previous day was a Sunday.

The matters were remanded to the first appellate authority for a decision on merit

For the Appellant/Greaves Cotton Ltd: Advocate Raghavan Ramabadran

For the Respondent/Revenue: Rajendran Raghavan, Senior Standing Counsel Greaves Cotton

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Case Title :  M/s Greaves Cotton Ltd. v. The Commissioner of GST and Central Excise (Appeals-II)Case Number :  CMA Nos. 2132 of 2026 and connected appealsCITATION :  2026 LLBiz HC(MAD) 282
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