DIN Not Mandatory if RFN Present: Andhra Pradesh High Court Upholds Validity of Digitally Signed GST Orders

“Reference Number Auto-Generated on GST Portal is Evidence of Digital Signature” –  In a significant decision reinforcing the validity of electronically generated GST notices and orders, the High Court of Andhra Pradesh on 9 February 2026 dismissed Writ Petition, holding that absence of a separate Document Identification Number (DIN) does not vitiate assessment orders if a Reference Number (RFN) is auto-generated upon digital signing.

A division bench of Justice R. Raghunandan Rao and Justice T.C.D. Sekhar ruled that the challenge to GST assessment and recovery proceedings on technical grounds was unsustainable, especially when there was no explanation for the delay in approaching the court after the rejection of appeal.

“Digital Signature is Inherent in Portal-Issued GST Orders” – No Physical Signature Required

The petitioner, Kudos Facility Services, assailed an assessment order dated 12.06.2024 and a subsequent attachment notice dated 19.12.2025 issued under Section 79 of the CGST Act, contending that the orders were invalid due to lack of DIN and absence of physical or digital signatures on pre-assessment notices (Forms DRC-01A and DRC-01).

Rejecting this argument, the Court held: “The presence of a RFN number is sufficient for the Court to hold that a digital signature has been affixed on the said documents. The contention of the petitioner relating to the absence of signatures has to be negatived.” [Para 10]

Citing its previous orders dated 26.09.2025 and 31.01.2026, the Court observed that all GST orders issued through the official portal are inherently digitally signed. The Reference Number (RFN), automatically generated at the time of uploading, is itself the proof of authentication and digital signature.

“The DIN/Reference Number is generated by the portal itself... and would be exclusively assigned to a particular order.” [Para 11]

Delay is Fatal in Writ Jurisdiction: Petition Dismissed for Laches

Apart from the technical challenge, the Court strongly disapproved of the unexplained delay in pursuing legal remedies.

The timeline revealed:

• Assessment Order issued: 12.06.2024

• Appeal filed: 12.09.2024

• Appeal rejected: 16.07.2025

• Recovery Notice issued: 19.12.2025

• Writ filed: After 19.12.2025

Despite the considerable passage of time, the petitioner offered no valid explanation for the delay either in filing the appeal or the writ petition. The Court noted:

“In the absence of explanation for the delay, the present writ petition is liable to be dismissed on the ground of laches.” [Para 8]

The Court further dismissed the excuse that the petitioner lacked portal access skills, pointing out that the petitioner had previously filed objections on the portal, showing clear awareness of proceedings.

GST Assessment and Recovery Mechanism Upheld

The High Court concluded that once the assessment order was validly issued and appeal rejected, the initiation of recovery under Section 79 of the CGST Act was lawful, and there was no cause to interfere under Article 226.

“None of the grounds raised in the writ petition are tenable and there are no merits in the present writ petition.” [Para 12]

Accordingly, the writ petition was dismissed, with the Court also directing that any pending applications stand closed.

This judgment decisively reiterates the principle that procedural formalities in GST proceedings—such as DIN or physical signatures—cannot override the substance of validly issued and digitally signed orders, especially when Reference Numbers generated on the GST portal serve the same purpose. The High Court has also made it clear that writ jurisdiction cannot be invoked belatedly, especially when statutory appellate remedies have already been exhausted without explanation.

Date of Decision: 09 February 2026