Rajasthan High Court Upholds GST Penalty Order Despite Absence Of DIN, Says RFN Is Sufficient

The Rajasthan High Court has held that a GST order communicated through statutorily recognised modes such as the GST portal, registered post or e-mail cannot be invalidated merely because it does not mention a Document Identification Number (DIN), where the communication carries a verifiable Reference Number (RFN).

“Once service has been effected in any of the recognised statutory modes, we are of the view that the requirement of lawful communication clearly stands satisfied,” a division bench of Justice Arun Monga and Justice Sunil Beniwal observed.

The court dismissed a writ petition filed by Mahesh Trivedi challenging a penalty order passed by the Joint Commissioner, Central Goods and Services Tax, Udaipur. The penalty order held that the petitioner had wrongfully availed Input Tax Credit worth Rs. 32.29 crore without actual receipt of goods or services and fraudulently passed on ITC worth Rs. 30.97 crore through 32 fictitious entities.

Senior Advocate Vikas Balia, appearing for the petitioner along with Prateek Gattani, argued that the impugned order was void because it did not contain a DIN as required under CBIC circulars issued in 2019. The petitioner contended that any communication issued without DIN was “non est in law and deemed to have never been issued.”

Rejecting the contention, the bench noted that every page of the impugned order carried the number “I/3740446/2025” on the top-right corner. Counsel for the respondents informed the court that the number was an RFN and that entering it on the GST portal successfully retrieved the impugned order.

“This goes on to show that the RFN appearing on the order is a unique and verifiable electronic identifier linked to the impugned communication. The very purpose of providing access and service of the same to the petitioner is thus achieved as per the requirement of law," the court observed.

The bench further referred to Section 169 of the CGST Act, which recognises service of notices and orders through modes including registered post, e-mail, and uploading on the common portal.

The court noted that the impugned order itself recorded that it had been uploaded on the official portal and dispatched through registered post as well as e-mail.

The court held that even assuming no DIN or RFN had been mentioned, the petitioner's argument would still not succeed because the order had been communicated through recognised statutory modes.

“Therefore, where the order has been duly communicated through these prescribed modes, service of the order cannot be invalidated merely on a technical objection relating to nomenclature of the identification number.,” the bench said.

The bench also relied on a CBIC circular dated June 9, 2025, which clarified that communications generated through the GST common portal already bear a verifiable RFN and need not separately mention a DIN.

“In respect of communications generated through the GST portal, the RFN serves the same functional purpose of traceability, authenticity and verification as a DIN. Therefore, absence of the label “DIN” does not render such communication invalid where a verifiable RFN is already available.,” the court held.

For Petitioner: Senior Advocate Vikas Balia assisted by Prateek Gattani

For Respondents: Additional Advocate General Mahaveer Bishnoi; Nilesh Choudhary for Kuldeep Vaishnav