What is a Document Identification Number and how does it work?

The Central Board of Indirect Taxes and Customs (CBIC) has made it mandatory to generate and quote a DIN on any communication issued by CBIC officials to taxpayers and other concerned persons from 8 November 2019 vide Circular No. 122/41/ 2019. Issuance of certain communications without a DIN is permitted under certain specific circumstances, however the same has to be modified by the Ministry by obtaining post-facto approval within 15 days. This article discusses the Document Identification Number on a GST Notice.

What does DIN stand for?

DIN stands for Document Identification Number. This is a 20-digit unique number generated digitally in an alphanumeric code. The Central Board of Indirect Taxes and Customs (CBIC) has come up with an initiative to digitize all communications sent by tax officials to registered taxpayers. A unique document identification number will be used in all messages sent to taxpayers.

Purpose and Benefits of DIN under GST

The following benefits will accrue to the taxpayer from the Document Identification Number on any communication from the GST Department:

• Transparency of all communication with the department to prevent receipt of false reports and easy identification of such false reports.
• Creating a proper audit trail of all communications sent by the department.
• Protect the rights of taxpayers.

Importance of DIN

Many times it happens that notices/summons are issued through unofficial email IDs. The implementation of the document identification number ensures the authenticity of such notifications and protects the taxpayer from unnecessary harassment. Therefore, the taxpayer must confirm the Document Identification Number before responding to any notice.

Application of DIN

Henceforth, the document identification number will be used in GST cases where investigations are underway and arrest/search warrants have been issued. The use of the document identification number in such communication will confirm its authenticity. The taxpayer can confirm the authenticity of the communication by entering such DIN in the “VERIFY CBIC-DIN” window at www.cbic.gov.in. The window will only report information if the communication is genuine.

Validity of notices issued without DIN

DIN is a mandatory requirement for all communication with the taxpayer. Any such communication issued without a document identification number is invalid. They are considered invalid to the limit of their issuance. In exceptional circumstances, however, the notice may be issued without a document identification number. In such cases, the tax officials should indicate that it is issued without a document identification number and its justification. There may be cases where a notice is issued without a document identification number, for example:

• Technical defects
• The authorized officer is out of the office performing official duties and notice must be issued immediately.

In such cases, the Tax Officers may issue a document identification number within 15 days of the issue of the communication.

Final words

The CBIC has also directed that any specified communication which does not carry an electronically generated DIN and is not covered under specified circumstances shall be deemed void and deemed never issued.

Therefore, if the notice received by the taxpayer does not mention the DIN, it would be considered void ab initio and need not be answered. However, since this CBIC instruction applies only to CBIC officers, notifications issued by state GST officers may still be issued without a DIN.