M/S. Kagga Pandu Ranga Rao vs. The Assistant Commissioner (St)
Held
The High Court, relying on Supreme Court and its own Division Bench precedents, held that an assessment order lacking a DIN is non-est and invalid, as per the circular issued by the Central Board of Indirect Taxes and Customs (CBIC). The impugned assessment order was set aside, with liberty to the respondent to conduct fresh assessment after assigning a DIN.
Facts
The petitioner challenged an assessment order (FORM GST DRC-07) issued by the Assistant Commissioner ST for tax periods 2021-2022 to 2024-2025. The primary ground for challenge was the absence of a Document Identification Number (DIN) on the order and lack of personal hearing. The respondent admitted that the impugned order did not contain a DIN.
Key Issues
Whether an assessment order issued under the GST Act without a Document Identification Number (DIN) is valid, and if its absence renders the order non-est in the eyes of law.
AI-generated summary — verify with the full judgment below
Date of reserved for orders : nil Date of pronouncement : 15.07.2026 Date of uploading : 21.07.2026 APHC010354852026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3543] WEDNESDAY, THE 15th DAY OF JULY 2026 PRESENT THE HONOURABLE SRI JUSTICE NINALA JAYASURYA THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 19153/2026 Between:
M/S. KAGGA PANDU RANGA RAO, HAVING THEIR REGD. PREMISES AT D. NO. 24/28/1-38/27, H' FLOOR, PUNNAIAH COLONY, LANE, GULABI THOTA, VIJAYAWADA-520 011
...PETITIONER AND 1. THE ASSISTANT COMMISSIONER ST, GANDHI NAGAR CIRELE, KMR AND SONS PLAZA, 2ND FLOOR, KRISHNA NAGAR, YANAMALAKUDURU ROAD, VIJAYAWADA-7
THE STATE OFANDHRA PRADESH, REP BY ITS PRINEIPAL SEERETARY REVENUE (CT) DEPT., VELAGAPUDI, AMARAVATI- 522 237
...RESPONDENT(S): Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased topleased to issue an appropriate Writ, Order or Eirection, more particularly one in the nature of WRIT OF MANDAMUS declaring the impugned Assessment Order vide FORM GST D
The judgment continues below.
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Reproduced from the public record of the Andhra Pradesh High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.