Facts of the Case

Pedda Venkatesu Challa was served a series of assessment orders/proceedings in Form GST DRC-07, all dated 22.01.2025, passed under Section 74(1) of the APGST Act, 2017 for the financial years 2017-18 through 2023-24 (upto September 2023). He challenged these orders as illegal and arbitrary, contending among other grounds that they were issued without any Document Identification Number, which the Government Pleader for Commercial Tax, on instructions, did not dispute.

Issues Involved

  1. Whether a series of multi-year GST assessment orders that carry no Document Identification Number can be sustained.

Petitioner's Arguments

  • Relied on the Supreme Court's decision in Pradeep Goyal v. Union of India holding an order without a DIN to be non-est and invalid.
  • Relied further on this Court's Division Bench rulings in M/s. Cluster Enterprises and Sai Manikanta Electrical Contractors, applying the CBIC's DIN circular to require orders lacking a DIN to be set aside.

Respondent's Arguments

  • The Government Pleader for Commercial Tax, on instructions, confirmed there was no DIN on the impugned orders.

Court Order / Findings

  • In light of Pradeep Goyal and the coordinate precedents, the non-mention of a DIN in the orders uploaded to the portal required them all to be set aside.
  • Liberty was granted to the third respondent to conduct a fresh assessment for each of the years, after giving notice to the petitioner and assigning a DIN to any fresh order.
  • The period from the dates of the impugned orders till receipt of the present order was excluded for limitation purposes; no order as to costs.

Important Clarification

  • The DIN requirement applies with equal force to a bundle of multi-year assessment orders issued together; the absence of a DIN on even a batch of orders across several financial years is fatal to all of them, not merely a technical irregularity confined to one year.

Sections Involved

  • Section 74(1) of the APGST Act, 2017 — determination of tax involving fraud, wilful misstatement or suppression.
  • CBIC Circular No. 128/47/2019-GST — mandatory Document Identification Number for GST communications.

Decision – In Favour of

In favour of the Assessee — all impugned assessment orders were set aside for want of a DIN, with liberty to the department to reassess after issuing a proper DIN.

Case Details

Court: High Court of Andhra Pradesh at Amaravati — Case No.: Writ Petition No. 16149 of 2025 — Coram: Hon'ble Justices R. Raghunandan Rao and Sumathi Jagadam — Date of Order: 2 July 2025.

Link to Download the Order

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