Mandatory DIN in CBIC Communications to Taxpayers – Compliance Update.

The Central Board of Indirect Taxes and Customs (CBIC) has issued an important clarification regarding the Document Identification Number (DIN) requirements for communications sent through the GST common portal. This development brings welcome relief to tax officers and streamlines the communication process with taxpayers.

Background: The Evolution of DIN Requirements

The journey began with CBIC’s commitment to transparency and accountability in tax administration. Through Circular No. 122/41/2019-GST dated November 5, 2019, and its subsequent expansion via Circular No. 128/47/2019-GST dated December 23, 2019, the Board mandated the generation and quoting of Document Identification Number (DIN) on all communications with taxpayers and other stakeholders.

This initiative was designed to leverage technology for greater accountability and transparency, ensuring that every official communication could be tracked and verified. Initially applied to specified documents, the requirement was later expanded to cover all communications, including emails, sent by any CBIC office.

The Dual Number Dilemma

However, a practical issue emerged with the implementation of this policy. The GST common portal, which serves as the primary platform for official communications under Section 169(1)(d) of the CGST Act, 2017, automatically generates documents with a Reference Number (RFN).

Key Features of RFN:

• Automatic Generation: Every document created through the GST portal receives an RFN
• Verifiable: Can be verified at https://services.gst.gov.in/services/verifyRfn
• Comprehensive Details: Verification provides complete document information including:
  • Date of RFN generation
  • Date of document issuance
  • Module information
  • Type of communication
  • Name of the issuing office

The Problem of Redundancy

The Board recognized that requiring both RFN and DIN on the same communication created unnecessary complexity. Documents generated through the GST portal would carry two different electronically generated, verifiable unique numbers, which served essentially the same purpose of ensuring traceability and accountability.

This redundancy was particularly evident in critical communications such as:

• Show Cause Notices in Form GST DRC-01
• Orders-in-Original in Form GST DRC-07

As emphasized in Instruction No. 4/2023-GST dated November 23, 2023, these documents must be served electronically through the common portal, making them automatically eligible for RFN generation.

The Clarification: Streamlined Communication Process

In recognition of this redundancy, CBIC has now clarified that communications sent via the GST common portal that already bear a verifiable Reference Number (RFN) do not require an additional Document Identification Number (DIN).

Key Takeaways:

1. RFN Suffices: For portal-generated communications, RFN serves as adequate identification
2. Legal Validity: Communications bearing only RFN are considered valid official communications
3. Compliance Maintained: This approach still ensures full compliance with Section 169 of the CGST Act, 2017
4. Simplified Process: Eliminates the burden of generating dual identification numbers

Impact on Tax Administration

This clarification brings several benefits to the GST ecosystem:

For Tax Officers:

• Reduced Administrative Burden: No need to generate separate DINs for portal communications
• Streamlined Workflow: Faster processing of communications
• Clear Guidelines: Eliminates confusion about dual numbering requirements

For Taxpayers:

• Consistent Experience: Single reference number for all portal communications
• Easy Verification: Continued ability to verify documents through the portal
• No Impact on Rights: All legal protections and verification mechanisms remain intact

Modification of Previous Circulars

This clarification effectively modifies the earlier circulars (No. 122/41/2019-GST and No. 128/47/2019-GST) to the extent they required DIN on portal communications that already have RFN. The original intent of ensuring accountability and transparency remains fully preserved while eliminating unnecessary procedural complexity.

Moving Forward

Tax officers and stakeholders should note that this clarification applies specifically to communications generated through the GST common portal. For other communications that do not originate from the portal and lack RFN, the DIN requirements continue to apply as per the original circulars.

This pragmatic approach by CBIC demonstrates the Board’s commitment to both transparency and operational efficiency, ensuring that technology serves to simplify rather than complicate the tax administration process.

Conclusion

The CBIC’s clarification represents a balanced approach to maintaining accountability while reducing administrative burden. By recognizing that RFN serves the same purpose as DIN for portal communications, the Board has eliminated redundancy without compromising on transparency or taxpayer rights.

This development should be welcomed by tax practitioners and officers alike, as it streamlines processes while maintaining the robust verification and accountability framework that modern tax administration demands.

Notification Reference: GST
Circular No. 249/06/2025
09/06/2025