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DIN Not Mandatory If Documents Is Communicated Through Common Portal And If It Bear Verifiable Reference Number (RFN) – Prospective or retrospective ??

Summary: Documents communicated through the common GST portal, bearing a verifiable reference number (RFN), do not require a Document Identification Number (DIN). This specific exemption, clarified by Circular No. 249/06/2025-GST dated June 9, 2025, modifies previous circulars that broadly mandated DIN for all communications, including emails, from December 24, 2019. Previously, certain communications like search authorizations and summons required DIN from November 8, 2019, with any communication lacking a DIN being considered invalid. GST communication methods include direct tendering by officers, messenger, registered or speed post, email, common portal availability, and newspaper publication. The exemption for RFN-bearing common portal communications means they are considered valid without a DIN. The verifiability of the RFN can be confirmed on the official GST portal. Regarding the application of such changes, the Supreme Court in Suchitra Components Ltd. Vs. Commissioner ruled that beneficial circulars apply retrospectively, while oppressive ones apply prospectively, which suggests that this DIN exemption could be applied retrospectively if considered beneficial to the assessee.

Mode of Communication and Service of notice under GST

1.Any decision, order, summons, notice or other communication under GST Act or GST rules made thereunder shall be served by any one of the following methods, namely

2. Giving or tendering directly by GST officers.

3. By a messenger including a courier

4. By registered post or speed post or courier with acknowledgement due

5. By sending a communication to e-mail address provided at the time of registration

6. By making it available on the common portal/GSTIN.

(Now this mode of communication is exempted from DIN if such communication bear verifiable RFN -reference number)

7. By publication in a newspaper 

8. Circular No. 122/41/2019-GST dated 5th November, 2019 [DIN made mandatory only for following specific communication]

no search authorization, summons, arrest memo, inspection notices and letters issued in the course of any enquiry shall be issued by any officer under the CBIC to a taxpayer or any other person, on or after the 8th day of November, 2019 without a computer generated Document Identification Number (DIN) being duly quoted prominently in the body of such communication.

any specified communication mentioned above which does not bear the electronically generated DIN shall be treated as invalid and shall be deemed to have never been issued.

 Circular No.128/47/2019-GST dated 23rd December, 2019 [DIN made mandatory for all communication including email]

Document Identification Number (DIN) shall be done in respect of all communications (including e-mails) sent to tax payers and other concerned persons by any office of the Central Board of Indirect Taxes and Customs (CBIC) across the country on or after the 24th day of December, 2019

 any communication which does not bear the electronically generated DIN, shall be treated as invalid and shall be deemed to have never been issued.

 Circular No. 249/06/2025-GST dated 09-06-2025

communications via common portal (GSTIN/ waybills) having verifiable  Reference Number (RFN), quoting  of  Document  Identification  Number  (DIN)  is  not  required and such communication bearing Reference Number  (RFN) is to be treated as a valid communication.

To  the  above  extent, Circular No. 122/41/2019-GST dated 5th November, 2019   and   128/47/2019-GST   dated   23.12.2019 issued   by   the   Board, stands modified

Verifiable RFN -reference number means

verifiable through the portal at https://services.gst.gov.in/services/verifyRfn

 In the case of Suchitra Components Ltd. Vs. Commissioner 2008(11) ST- R430(SC), Hon’ble Supreme Court held that a beneficial Circular must be applied retrospectively by the Assessee while oppressive circular must be applied prospectively. Thus, when the circular is against the Assessee, they have right to claim enforcement of the same prospectively

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