The Andhra Pradesh High Court has clarified that electronic compliance under the Goods and Services Tax Act does not require physical signatures or a traditional Document Identification Number (DIN), affirming that digitally generated Reference Numbers (RFN) suffice for legal validity. This ruling resolves longstanding ambiguity for tax practitioners and reinforces the primacy of digital procedural compliance in modern tax administration.
Background & Facts
The Dispute
The petitioner, M/S. Pedda Masthan Enterprises, a registered dealer in ferrous waste trading, challenged two orders issued under the GST Act: an assessment order dated 28.10.2023 by the 1st Respondent and its corresponding summary order in Form DRC-07 dated 26.12.2024 by the 2nd Respondent. The petitioner contended that both orders were invalid because they lacked physical or electronic signatures and the summary order did not bear a DIN.
Procedural History
- August 2022 to February 2023: Tax period under scrutiny
- 13.04.2023: Authorization granted to assess petitioner
- 25.05.2023: Pre-show cause notice (DRC-01A) issued
- 05.07.2023: Show cause notice (DRC-01) issued under Section 74 and Section 122(2)(ii)
- 05.08.2023: Petitioner’s GST registration cancelled with effect from 30.06.2023
- 28.10.2023: Assessment order passed and uploaded on portal
- 26.12.2024: Summary order (DRC-07) uploaded on portal
- January 2026: Writ petition filed under Article 226 seeking quashing of orders and stay of penalty
Relief Sought
The petitioner sought: (a) declaration that the assessment and summary orders are illegal for lack of signatures and DIN; (b) quashing of both orders; (c) direction to reissue orders following principles of natural justice; and (d) stay of recovery of Rs. 3.34 crore penalty pending disposal.
The Legal Issue
The central question was whether an assessment order and its summary under the GST Act are legally invalid if they lack a physical signature or a traditional Document Identification Number (DIN), and whether the presence of a Reference Number (RFN) generated through the portal satisfies statutory and procedural requirements.
Arguments Presented
For the Petitioner
The petitioner relied on Circular No. 122/41/2019-GST and prior judgments of the same High Court to argue that: (1) physical or electronic signatures are mandatory for validity; (2) DIN is a statutory requirement under GST procedural rules; and (3) absence of either renders the orders void ab initio. It further contended that its delay in filing the writ was excusable due to ongoing litigation over prior assessments and inability to access the portal after registration cancellation.
For the Respondent
The State countered that: (1) all orders were uploaded electronically on the GST portal on the date of issuance; (2) digital signatures are inherently embedded in portal-generated documents and automatically trigger an RFN; (3) the RFN serves as the functional equivalent of DIN; and (4) the petitioner’s delay of over one year in filing the writ - without any explanation - constitutes laches, warranting dismissal on procedural grounds alone.
The Court's Analysis
The Court examined the nature of digital compliance under the GST regime and the evolution of procedural norms on the GST portal. It noted that the petitioner’s challenge was not novel, having been previously addressed in W.P. No. 14874 of 2025, which this Court had already settled.
"This Court is convinced that the show-cause notice, in Form GST DRC-01 and the summary of the assessment order, in Form GST DRC-07, have to be issued electronically and they cannot be issued electronically, unless the said proceedings have been digitally signed by the issuing authority. Further, the affixture of any digital signature on any document or proceeding would automatically generate an Identification Number, called the RFN Number."
The Court held that the presence of the RFN - ZD3712240385479 - in the summary order was conclusive proof of digital authentication. The portal’s automated generation of RFN upon digital signing renders the physical signature redundant. The Court emphasized that the GST system operates on a digital-first framework, and technical compliance must be interpreted in light of system architecture, not analog expectations.
Regarding the DIN, the Court clarified that the term is no longer used in its traditional sense post-portal integration. The RFN is the system-generated, unique identifier that fulfills the same function. The Court further rejected the petitioner’s excuse for delay, noting that even after registration cancellation, access to historical assessment records remained available on the portal. The absence of any explanation for the year-long delay rendered the petition liable to dismissal on the doctrine of laches.
The Verdict
The writ petition was dismissed. The Court held that digital signatures and RFN numbers generated through the GST portal satisfy statutory requirements for validity of assessment and summary orders, and that laches bars relief where no explanation is offered for undue delay in filing.
What This Means For Similar Cases
Digital Authentication Supersedes Physical Signatures
- Practitioners must now argue that electronic signatures and RFN are legally sufficient under GST law
- Challenges based on absence of physical signatures on DRC-01 or DRC-07 forms are no longer tenable
- Tax authorities need not reissue orders for lack of manual signatures
RFN Is the Functional DIN
- RFN is the new standard for document identification in GST proceedings
- Any order bearing an RFN is presumed to be digitally signed and procedurally valid
- Petitioners must verify RFN presence before challenging orders on DIN grounds
Delay in Filing Writs Will Be Penalized
- Delay exceeding six months without explanation invites dismissal on laches
- Access to portal records post-registration cancellation does not excuse inaction
- Practitioners must file writs within 3-4 months of order issuance to avoid procedural bars
