Critical Legal Role of DIN under GST: CBIC Circulars, Compliance Requirements & Clarification on DIN vs RFN

Introduction

In light of recent developments, the Central Board of Indirect Taxes and Customs (CBIC) has issued a new circular concerning the applicability and procedural implications of the Document Identification Number (DIN) under the Goods and Services Tax (GST) regime. This article provides a comprehensive and chronological analysis of the DIN framework-from its inception through Circular No. 122/41/2019-GST to the most recent clarification under Circular No. 249/06/2025-GST.

By examining each circular in sequence, the article elucidates the evolving legal significance of DIN, its mandatory nature, exceptions permitted under exigent circumstances, and its interplay with Reference Numbers (RFNs) on portal-generated communications. Readers will gain a clear understanding of why quoting a valid DIN or RFN is not merely a procedural formality but a statutory requirement, the violation of which may render departmental communications legally non-est.

1. Circular 122/41/2019-GST (dt. 05-11-2019) - Genesis of the DIN Regime

• Purpose & Policy trigger - In the wake of C&AG observations on un-traceable departmental letters, CBIC introduced a computer-generated 20-digit Document Identification Number (DIN) to guarantee traceability, auditability and non-repudiation of every sensitive communication.
• Phase-I Scope - Mandatory for search authorisations, inspection orders, summons, arrest memos, offence notices and enquiry letters issued on or after 08 Nov 2019.
• DIN architecture - Format CBIC-YYYY-MM-ZCDR-NNNNNN where "ZCDR" maps the issuing Zone / Commissionerate / Division / Range; the last six characters are system-generated. Generation is routed exclusively through the DDM portal; each new request yields a fresh DIN.
• Validation & public verification - Recipients can authenticate any DIN on a "VERIFY CBIC-DIN" window hosted on cbic.gov.in; the screen returns the issuing office and date of generation.
• Stringent consequence - Any communication lacking DIN is "non-est" in law unless covered by the "technical exigency" escape clause that requires ex-post-facto approval of the Principal Commissioner/ Commissioner within 24 hours.

Permitted Exceptions to the Mandatory DIN Requirement

Whereas DIN is a mandatory requirement, in exceptional circumstances, communications may be issued without an auto-generated DIN. However, this exception is permissible only after recording detailed reasons in writing in the relevant file, and the communication must expressly state that it has been issued without DIN.

Exigent situations recognised (Para 3 of the Circular)

1. Technical difficulties - Genuine system outages hindering DIN generation.

2. Field-level urgency - Investigations/enquiries/verifications that must be initiated at short notice while the authorised officer is outside the office discharging official duties.

Mandatory Post-Facto Regularisation (Para 6)

Any communication issued without DIN under the above exigencies must be regularised within 15 working days by completing all three of the following steps:

Failure to complete any of these actions within the 15-day window renders the communication vulnerable to challenge as invalid.

2. Circular 128/47/2019-GST (Dated 23-12-2019) - Universal Mandate for DIN on All Communications

Expanded Scope and Mandatory ImplementationFollowing the successful rollout of DIN for key enforcement actions under Circular 122/41/2019-GST, CBIC issued Circular 128/47/2019-GST mandating electronic generation and quoting of DIN in all forms of communications - including e-mails, letters, SCNs, orders, audit memos, deficiency memos, and reminders - issued by any CBIC officer to taxpayers or stakeholders across the country.

Key Legal Directives:

• Effective Date: The universal DIN mandate came into force w.e.f. 24.12.2019, and applies uniformly to all communications issued by CBIC offices.
• DIN Platform Enhancement: The DDM portal (https://cbicddm.gov.in) was upgraded to facilitate DIN generation for all forms of official correspondence, ensuring seamless digital traceability and transparency.
• Standardised Formats with Pre-populated DIN:

The Board directed all field formations to adopt harmonised templates for summons, inspection notices, arrest memos, provisional release orders, etc., with auto-populated DINs, effective 01.01.2020.

• E-mail Compliance: Even e-mails sent by GST officers must bear a system-generated DIN.
• Mandatory Nature of DIN: Any communication not bearing a DIN (unless covered by the specific exceptions laid down in Para 3 of Circular 122/41/2019-GST) is to be treated as invalid and non-est in law.

Clarification of Legal Position

"Any specified communication which does not bear the electronically generated DIN and is not covered by the exceptions mentioned in paragraph 3 of Circular No. 122/41/2019-GST dated 05.11.2019, shall be treated as invalid and shall be deemed to have never been issued."

This statement elevates DIN compliance to a binding procedural safeguard, failure of which renders such communication legally void.

3. Instruction 04/2023-GST (dt. 23-11-2023) - Electronic Service Enforcement

Statutory mooring - Anchored in Rule 142, CGST Rules and Sec 169(1)(d), CGST Act.

Mandates -

• DRC-01 (summary of SCN) and
• DRC-07 (summary of Order-in-Original)

must be uploaded on the GST common portal; mere physical or e-mail service is non-compliant. Zonal Chiefs were told to ensure 100 % portal service and report deviations.

4. Rule 142, CGST Rules - Digital Demand Workflow

Failure to honour these e-workflow steps vitiates recovery and has led High Courts to quash demands.

5. Section 169(1)(d), CGST Act - Portal Service as Valid Service

Any "decision, order, summons, notice or other communication" "made available on the common portal" is deemed served-obviating physical delivery. This statutory deeming fiction underpins the CBIC's entire e-service strategy.

6. Case-law: Raam Autobahn India (P.) Ltd. v. ACST (AP HC, 2024)

The Court declared an assessment order invalid ab initio because it lacked a DIN, reiterating that Circular 122/41/2019 is binding on field officers; technical lapses not covered by the exception clause are fatal.

7. Circular 249/06/2025-GST (dt. 09-06-2025) - Resolving the DIN-RFN Overlap

7.1 Why the Clarification?

Portal-issued documents (SCNs, O-I-Os, acknowledgements) already carry a system-generated Reference Number (RFN) which is independently verifiable at https://services.gst.gov.in/services/verifyRfn. Simultaneous insistence on DIN created dual identifiers, operational confusion and clerical errors.

7.2 Key Clarifications (Point 2, 4-6)

Key Legal Observation

It is abundantly clear from the foregoing analysis that quoting either a Document Identification Number (DIN) or a Reference Number (RFN) is of critical legal significance in GST litigation. Any departmental communication-whether a notice, order, or memo-not bearing a valid DIN or RFN may be treated as invalid and unenforceable in law. Such procedural infirmity has been recognized by judicial authorities as a substantial ground for quashing proceedings, particularly where the absence of DIN renders the issuance of key documents ultra vires.

Conclusion

Prior to the issuance of CBIC Circular No. 249/06/2025-GST dated 09.06.2025, both DIN and RFN were expected to be quoted in communications generated through the GST portal. However, post this clarification, it has been clarified that portal-generated documents bearing a valid RFN alone are sufficient for legal compliance, and quoting DIN is no longer mandatory in such cases. The administrative preference now clearly leans in favour of the RFN system, reducing reliance on DIN for electronically generated documents.

The author can also be reached at varunmukeshgupta96@gmail.com