M/S. Ravi Cotton Traders vs. The Assistant Commissioner (St)
Held
The High Court set aside the assessment order, reiterating that the absence of a DIN invalidates such orders. Acknowledging practical difficulties with online service, the Court remanded the assessment back to the Assessing Officer for fresh orders after providing an opportunity of hearing, conditional on the petitioner depositing 20% of the disputed tax.
Facts
The petitioner challenged a GST assessment order (Form GST DRC-07) issued under Section 74, alleging it lacked a DIN, was unsigned, and was passed without proper notice or opportunity of hearing. The petitioner also contested the rejection of their appeal as time-barred and subsequent recovery proceedings, arguing the assessment order was not properly served but merely uploaded to the portal.
Key Issues
The key legal issues were the validity of a GST assessment order lacking a Document Identification Number (DIN) and the sufficiency of service of such an order solely by uploading it to the GST portal, especially when challenged with delay.
Sections Cited
Section 74, Section 142(1A), Section 74(9), Section 75(6), Section 75(4), Section 79, Section 169(1)(d)
AI-generated summary — verify with the full judgment below
Date of reserved for orders : Date of pronouncement : 24.06.2026 Date of uploading : APHC010313392026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3591] WEDNESDAY, THE 24th DAY OF JUNE 2026 PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE TUHIN KUMAR GEDELA WRIT PETITION NO: 16480/2026 Between:
M/S. RAVI COTTON TRADERS, REPRESENTED BY SHRI VELIDI SRINIVASA RAO, ETUKURROAD, 20-18-259, SRIPATHI COTTON GINNING MILL, 7TH LANE, DS NAGAR, GUNTUR, ANDHRA PRADESH - 522 006. ...PETITIONER AND 1. THE ASSISTANT COMMISSIONER ST, PATNAM BAZAAR CIRCLE, GUNTUR I DIVISION D. NO 11-1-73/1, 1ST FLOOR, VASUNDHARA BUILDINGS, RAJAJI BHAVAN, JINNA TOWER CENTRE, GUNTUR, ANDHRA PRADESH - 522 001. 2. THE DEPUTY ASSISTANT COMMISSIONER ST, PATNAM BAZAAR CIRCLE, GUNTUR I DIVISION, D. NO 11-1-73/1, 1ST FLOOR, VASUNDHARA BUILDINGS, RAJAJI BHAVAN, JINNA TOWER CENTRE, GUNTUR, ANDHRA PRADESH - 522 001. 3. THE ADDITIONAL COMMISSIONER ST, APPELLATE AUTHORITY, VIJAYAWADA, D NO. 40-5-19/9B, BACK OF NVKR TOWERS, MOGALRAJAPURAM,VIJAYAWADA, ANDHRA PRADESH - 520 010. 4. THE STATE OF ANDHRA
The judgment continues below.
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