M/S. Repa Infra Private Limited vs. Additional Commissioner (St) (Fac)
Held
The High Court, relying on Supreme Court precedent, held that an assessment order without a DIN is non-est and invalid. It allowed the writ petition, setting aside the original assessment order and remanding the matter to the Assessing Officer for fresh adjudication, subject to the petitioner depositing 20% of the disputed tax.
Facts
The petitioner was subjected to an assessment order for the tax period 2019-20, which did not contain a Document Identification Number (DIN). An appeal against this order was dismissed by the appellate authority on grounds of being time-barred. The petitioner challenged both orders, arguing the assessment was void due to the missing DIN.
Key Issues
The key legal issues were whether an assessment order lacking a DIN is valid, and if a writ petition challenging the original assessment order is maintainable even after an appeal against it has been dismissed on limitation grounds.
Sections Cited
Section 16(2)(aa)
AI-generated summary — verify with the full judgment below
APHC010233552026
IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) [3529] WEDNESDAY, THE TWENTY NINETH DAY OF APRIL TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE T.C.D.SEKHAR WRIT PETITION NO: 12162/2026 Between:
M/S. REPA INFRA PRIVATE LIMITED,, REP. BY ITS DIRECTOR, MR. K. NAGA VENKATA SWAMY NAIDU, 72-14-8/5, 202, SHANMUKH HEIGHTS, BABA NAGAR, AVA ROAD, NEAR GAIL OFFICE RAJAHMUNDRY, EAST GODAVARI DISTRICT-533 106. ...PETITIONER AND 1. ADDITIONAL COMMISSIONER ST FAC, APPELLATE AUTHORITY, VIJAYAWADA-520 007. 2. ASSISTANT COMMISSIONER ST, ARYAPURAM CIRCLE, RAJAMAHENDRAVARAM ANDHRA PRADESH-533 104. 3. UNION OF INDIA, REP. BY ITS SECRETARY, MINISTRY OF FINANCE, JEEVAN DEEP BUILDING, 3RD FLOOR, SANSAD MARG, NEW DELHI-110 001. 4. CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS, GST POLICY WING, GOVERNMENT OF INDIA, MINISTRY OF FINANCE, NEW DELHI-110 066, REP. BY ITS COMMISSIONER (GST).
STATE OF ANDHRA PRADESH, REP. BY ITS PRINCIPAL SECRETARY TO GOVERNMENT, REVENUE (CT) DEPARTMENT, SECRETARIAT, VELAGAPUDI, AMARAVATI, GUNTUR DISTRICT- 522 2
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