Generation and quoting of Document Identification Number, shortly and popularly known as DIN, was introduced DIN in GST vide circular no. 122/41/2019-GST dated 5th November 2019. Notably, DIN is to be generated and quoted on all the communication sent by the departmental officers to the taxpayers and/ or any other concerned person.
The basic objective behind the introduction of DIN is to bring complete transparency and accountability under GST.
Initially, DIN was introduced for all communications relating to search authorizations; arrest memo; summons; inspection notices and letters issued during the course of any such inquiry.
However, later on, the same was introduced for all the types of communication issued by the departmental officers to the taxpayers/ any other concerned persons.
It is important to note that DIN was introduced and made mandatory in case of communication issued by the Central Departmental Officers. However, States were individually required to implement the same.In the present article let us go through each and every pin points relating to Document Identification Number (DIN) i.e. DIN and its structure thereof; steps to be followed for verification of DIN; DIN implementation procedure and consequence of communication issued without generation of DIN.
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DIN in GST and its structure
Document Identification Number (DIN) as the name itself says is a number based on which any document can be identified. Under the DIN document is issued an electronically generated number.DIN is a unique 20 digit identification code. The structure of DIN (i.e. 20 digit identification code) is explained hereunder
CBIC YYYY MM ZCDR NNNNNN
Parts of 20 digit identification code (DIN)
Corresponding denomination thereof
Central Board Indirect Tax Commissionerate
Calendar year in which DIN is generated
Month in which DIN is generated
Zone Commissionerate Division Range Code
6 digit randomly generated alphanumeric code
Steps for verification of DIN
The genuineness of the DIN can be verified by the taxpayers by following the below mentioned steps
STEP 1 – Visit cbic website ;
STEP 2 – Click ‘Verify CBIC-DIN’ option available on the homepage;
STEP 3 – Enter the Document Identification Number;
STEP 4 – Select ‘Communication Category’, ‘Communication Sub Category’ and ‘Stream’ from the drop-down list;
STEP 5 – Enter the characters mentioned in the image; and
STEP 6 – Click Submit.
Notably, if the DIN is correct/ valid, then, the information relating to the office that issued the communication and the date of generation of the DIN will be displayed. This proves that the documents is genuine and the same is duly issued by the respective departmental officer.
DIN application procedure
Vide circular no. 122/41/2019-GST dated 5th November 2019, the board directs affixing of DIN mandatory, effective from 8th November 2019, on all of the following documents –
- Search authorization;
- Arrest memo;
- Inspection notices;
- Letters issued during the course of the inquiry.
However, under the following exceptional circumstances, communication can be issued without DIN –
- In case there is any technical difficulty in generating DIN; or
- In case the communication is to be issued in short notice/ in an urgent situation and the respective authorized officer is not available in the office due to outside official duty.
Vide circular no. 128/47/2019-GST dated 23rd December 2019, with effect from 24th December 2019, the board directs affixing of DIN mandatory on all the communications sent to the taxpayers and any other concerned persons.
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DIN in GST : Implementation of Current position
As noted above vide circular no. 128/47/2019-GST dated 23rd December 2019, affixing DIN on all the communication issued to the taxpayers was made mandatory with effect from 24th December 2019.
However, here it is important to note that DIN was introduced and implemented by the Central Government and is accordingly applicable to all the Central Departmental Officers.
Whereas, all the State Governments were individually required to implement the same. Surprisingly, after the implementation of DIN by the Central Government, the individual State governments didn’t issued any notification/ circular in that regard.
Interestingly, only two states i.e. Karnataka and Kerala implemented generation and quoting of DIN for all the communication issued by the state tax officers to the taxpayers. Unfortunately, none of the other states implemented the same. This was ruining the very purpose of DIN.Henceforth, a public interest litigation was filed by Mr. Pradeep Goyal before the Hon’ble Supreme Court praying to issue a writ of mandamus/ any other appropriate writ or order or direction to take up all the necessary steps to implement the system of electronic generation of DIN with regard to all the communications sent by the state GST officers to the taxpayers.
Direction of Supreme Court
The observation and direction of Hon’ble Supreme Court in Pradeep Goyal vs. Union of India & ORS [2022 (8) TMI 216 – Supreme Court] are highlighted hereunder –
Observation of Hon’ble Supreme Court
- It will be in the larger public interest to implement the system for the electronic generation of DIN for all the communications sent by the State GST officers to the taxpayers/ other concerned persons.
- Implementation of a system of electronic generation of DIN in GST will surely bring transparency and accountability in GST.
Direction of Hon’ble Supreme Court
- Hon’ble Supreme Court directed the GST council as well as the Union of India to issue advisory/ recommendations/ instructions to all the respective states with regard to the implementation of the system of electronic generation of DIN in GST.
- It was also directed to implement the use of DIN in all the communications relating to GST.
Notably, Andhra Pradesh Government, vide circular no. 2 of 2022 dated 1st August 2022, became the third state to implement the system of mandatory electronic generation of DIN on any communication issued by the State GST officer to the taxpayers and any other concerned person.
Let’s hope the other states will soon issue the relevant circular and implement DIN and help in bringing transparency under GST.
Consequence of communication issued without generation of DIN
DIN implementation circular no. 122/41/2019-GST dated 5th November 2019 clearly stated that any communication which doesn’t bear the DIN will be treated as invalid and it will be deemed that such communication is never issued.
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