Verifiable Reference Number (RFN) validates GST communications, obviating the requirement for a separate Document Identification Number (DIN).

The petitioner challenged an order dated 09.12.2025 passed by the Joint Commissioner, Central Goods and Services Tax (CGST), Udaipur.

The impugned order imposed a penalty on the petitioner for the wrongful availing of Input Tax Credit (ITC) amounting to ₹32,29,10,192 and the fraudulent passing of ITC through 32 fictitious entities.

Following search and seizure operations under Section 67 of the CGST/RGST Act, a Show Cause Notice was issued and replied to before the penalty was finalized.

The petitioner sought to quash the order primarily on the ground that it did not bear a Document Identification Number (DIN), asserting it was non est in law as per CBIC Circulars.

1. Whether the absence of a Document Identification Number (DIN) renders an order non est and void ab initio when the order contains a verifiable Reference Number (RFN).

2. Whether the communication of an order via the common portal, registered post, and email constitutes valid service under the CGST Act despite the technical absence of a DIN.

Section 169 of the Central Goods and Services Tax Act, 2017, which recognizes service of orders via the common portal, registered post, or email as valid.

CBIC Circular No. 122/41/2019-GST and Circular No. 128/47/2019-GST regarding DIN requirements, as modified by the subsequent CBIC Circular dated 09.06.2025.

The Circular dated 09.06.2025 clarifies that for communications generated through the GST common portal bearing a verifiable Reference Number (RFN), the quoting of a DIN is not required and such communications are valid.

The court found that although the specific expression "DIN" was missing, every page of the impugned order bore a unique Reference Number (RFN) "I/3740446/2025".

During proceedings, the respondents demonstrated that this RFN allowed for the successful retrieval of the order from the GST portal, satisfying the legal requirement for a verifiable electronic identifier.

The court reasoned that under Section 169, statutory recognition is given to service through electronic uploads and emails; since the petitioner did not deny receipt through these modes, the service was lawful.

The court highlighted that the Circular dated 09.06.2025 explicitly modified previous mandates, stating that RFN serves the same functional purpose of traceability and authenticity as DIN, making the insistence on a separate DIN redundant for portal-generated documents.

The court declined to exercise its extraordinary writ jurisdiction due to the availability of an alternative statutory appellate remedy.

The court directed that the period spent prosecuting the writ petition be excluded from the limitation period should the petitioner choose to file a statutory appeal.