All you Need to Know About DIN (Document Identification Number)

Transparency through technology can take India forward by rooting out corrupt practices. One more step in that direction has been taken by the Central Government by introducing the concept of Document Identification Number (DIN). Salient features are as under:

What is a DIN?

In keeping with the Government’s objectives of transparency and accountability in indirect tax administration through the widespread use of information technology, the CBIC is implementing a system for electronic (digital) generation of a Document Identification Number (DIN) for all communications sent by its offices to taxpayers and other concerned persons. After the DIN is generated, the department shall print the page bearing the DIN and file it in the concerned file while also quoting the DIN on the communication. This measure would create a digital directory for maintaining a proper audit trail of such communication. Importantly, it would provide the recipients of such communication a digital facility to ascertain their genuineness.

From when will it be operational?

Circular No. 122/41/2019-GST dt. 05.11.2019 as well as Circular No. 37/2019 – Cus dt. 05.11.2019 has been issued to operationalize the DIN system from 08.11.2019.

What all communications would be covered under the DIN system?

To begin with (i.e. from 08.11.2019) the DIN would be used for search authorization, summons, arrest memos, inspection notices, and letters issued in the course of any inquiry. The Board therefore in exercise of its power under section 168(1) of the CGST Act, 2017/ Section 37B of the Central Excise Act, 1944 has directed that no search authorization, summons, arrest memo, inspection notices, and letters issued in the course of any inquiry shall be issued by any officer under the Board 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. The digital platform for the generation of DIN is hosted on the Directorate of Data Management (DDM)’s online portal “cbicddm.gov.in”

Subsequently, the DIN would also be extended to other communications. Also, there is a plan to have the communication itself bearing the DIN generated from the system.

Are there exceptions to DIN?

Whereas DIN is a mandatory requirement, in exceptional circumstances communications may be issued without an auto-generated DIN. However, this exception is to be made only after recording the reasons in writing in the concerned file. Also, such communication shall expressly state that it has been issued without a DIN. The exigent situations in which a communication may be issued without the electronically generated DIN are as follows:- (i) when there are technical difficulties in generating the electronic DIN, or (ii) when communication regarding investigation/inquiry, verification, etc. is required to issue at short notice or in urgent situations and the authorized officer is outside the office in the discharge of his official duties.

Also, any communication issued without an electronically generated DIN in the exigencies mentioned above shall be regularized within 15 working days of its issuance by (i) obtaining the post-facto approval of the immediate superior officer as regards the justification of issuing the communication without the electronically generated DIN; (ii) mandatorily electronically generating the DIN after post facto approval; and (iii) printing the electronically generated Pro-forma bearing the DIN and filing it in the concerned file.

What shall be the consequence if the document requiring DIN is issued without the same?

Except for the exceptional circumstances discussed above, a document requiring DIN but issued without quoting the same shall be treated as invalid and shall be deemed to have never been issued. Hence the taxpayer is not required to comply with such invalid documents. Also, the department cannot initiate any action based on such invalid documents.

How to generate the DIN?

It may be noted that at present the DIN is only required for the documents issued by the department. The taxpayer has to file the reply/comply manually. Hence only the department can generate DIN through the Directorate of Data Management (DDM)’s online portal “cbicddm.gov.in”. Detailed steps to generate the DIN are provided in the earlier referred circular (same is also attached).

Whether State department communications are also covered under DIN?

Till now State Government has not issued any circular for implementing the DIN system in their communications. Hence only communications by the CGST department as well as the Customs Department would be covered under the DIN system.

Way forward

The introduction of the DIN system in indirect taxation is a transformative step. In times to come it would enable entire communication between the taxpayer and the department over the online platform ushering greater transparency and cutting out harassment faced by the taxpayers.

Copy of circular issued under GST with respect to DIN is attached for ready reference here

Know More: FAQs on Unique Document Identification Number (UDIN)