1. Introduction
In the spirit of enhancing transparency and accountability in the Indian indirect tax regime, the Central Board of Indirect Taxes and Customs (CBIC) has progressively mandated the use of Document Identification Number (DIN) on communications issued by its officers. This system was institutionalised vide Circular No. 122/41/2019-GST and expanded through Circular No. 128/47/2019-GST.
The recent Circular No. 249/06/2025-GST dated 09 June 2025 refines this framework by clarifying that for communications generated via the common GST portal, the presence of a Reference Number (RFN) renders quoting a DIN unnecessary.
This article comprehensively explores the genesis, legal underpinnings, practical aspects, and implications of this Circular, ensuring tax professionals, taxpayers, and departmental officers are well-informed.
2. Background: What is DIN?
The Document Identification Number (DIN) was introduced to curb malpractices and ensure that every notice, summons, letter, or order issued by a CBIC officer is verifiable online. It brings about:
- Traceability: Ensuring authenticity of documents.
- Accountability: Preventing unauthorised or fake communications.
- Transparency: Empowering taxpayers to verify genuineness.
Key milestones include:
- Circular No. 122/41/2019-GST dated 05 November 2019: Mandated DIN for specified communications.
- Circular No. 128/47/2019-GST dated 23 December 2019: Extended the DIN requirement to all communications, including emails.
DIN must be generated from the dedicated utility and quoted on every manual or electronic communication unless exempted due to technical exigencies (which must be recorded and later regularised).
3. Reference Number (RFN) under GST Portal
Parallel to DIN, the GST common portal issues Reference Numbers (RFN) for communications like notices (e.g., DRC-01, DRC-07) and orders. These RFNs:
- Are system-generated.
- Are unique and verifiable at https://services.gst.gov.in/services/verifyRfn.
- Provide full traceability: date of generation, type of communication, module, issuing office.
Legal basis:
- Section 169(1)(d) of CGST Act, 2017: Deems service by making the document available on the common portal as valid service.
- Rule 142 of CGST Rules, 2017: Governs issuance of notices (DRC-01) and orders (DRC-07), ensuring they are uploaded electronically.
Additionally, Instruction No. 4/2023-GST dated 23 November 2023 directed strict adherence to electronic service norms.
4. Core Clarification under Circular No. 249/06/2025-GST
Key Clarification:
For communications generated through the common portal which already bear a verifiable RFN, quoting an additional DIN is not required.
This avoids duplication of unique numbers (RFN and DIN) on the same communication, which can cause confusion and redundancy.
In essence:
- Manual / offline / email communications: DIN mandatory.
- Portal-generated communications (DRC-01, DRC-07, etc.): RFN suffices, no DIN needed.
Thus, Circular No. 122/41/2019-GST and Circular No. 128/47/2019-GST stand modified to this extent only.
5. Legal and Administrative Implications
A. For Departmental Officers
- Must ensure DIN is generated and quoted for all non-portal communications.
- For portal communications, ensure RFN is correctly generated and communicated.
- Must not duplicate DIN on RFN-bearing portal documents.
B. For Taxpayers
- Should verify RFNs via the GST portal to confirm authenticity.
- For any manual or email communication, should check the DIN at CBIC’s DIN verification utility.
- Any document without DIN or RFN should be treated with caution and verified with the jurisdictional office.
6. Practical Scenarios
| Scenario | DIN Required? | RFN Required? |
|---|---|---|
| Show Cause Notice (DRC-01) via portal | ❌ | ✅ |
| Order-in-Original (DRC-07) via portal | ❌ | ✅ |
| Summons issued manually by officer | ✅ | ❌ |
| Notice sent by email by officer (not through portal) | ✅ | ❌ |
| Demand notice generated outside the portal due to technical issues | ✅ | ❌ (RFN not generated) |
7. Compliance Checks and Good Practices
- Department: Use DIN generation utility diligently for manual docs.
- Taxpayers: Verify RFN via GST portal link; verify DIN via CBIC’s DIN verification portal.
- Advisors: Educate clients that DIN/RFN safeguards them from fraud and helps track communications.
8. Latest Developments & Way Forward
This rationalisation aligns with CBIC’s digital governance drive:
- Avoids redundant data points.
- Simplifies backend validation.
- Balances administrative efficiency with taxpayer protection.
With RFN and DIN, the CBIC ensures every communication is digitally traceable, thus fortifying India’s digital tax administration.
9. Conclusion
Circular No. 249/06/2025-GST reflects CBIC’s commitment to rationalising procedures without compromising transparency. By clarifying that RFN suffices for portal-based communications, the Board prevents confusion and ensures smooth, traceable interactions.
Tax professionals must adapt internal checklists to reflect this distinction, train staff, and guide clients accordingly.
10. Key Takeaway
👉 Always verify:
- DIN → For manual/offline/email notices.
- RFN → For communications issued through GST portal.
References
- CGST Act, 2017 – Section 169(1)(d)
- CGST Rules, 2017 – Rule 142
- CBIC Circular No. 122/41/2019-GST
- CBIC Circular No. 128/47/2019-GST
- CBIC Instruction No. 4/2023-GST
- CBIC Circular No. 249/06/2025-GST
This article is intended for general awareness and does not constitute professional advice. For specific cases, consult your GST advisor.
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