The Delhi High Court has delivered a detailed judgment on the interplay between a digitally signed portal-generated order and its incorporated annexure where the two are mutually inconsistent, holding that the Portal Order recording 'proceedings dropped' cannot be read in isolation from the Annexure to which it expressly refers, and that a Corrigendum correcting the inconsistency is a valid rectification under Section 161 of the CGST Act. The ruling by Justice Anil Kshetarpal and Justice Shail Jain in W.P.(C) 7339/2024 (Kapil Raj Anand, decided 08.09.2026) addresses a recurring practical difficulty arising from the architecture of the GST portal and provides authoritative guidance on the relationship between automated portal outputs and their detailed annexures.
The petitioner's SCN under Section 73 for FY 2018-19 raised four issues. The Portal Order, digitally signed and titled 'Order for dropping the proceedings', stated that proceedings were dropped 'for the reasons and other details stated in the Annexure attached herewith'. However, the Annexure — separately headed 'ORDER' — rejected the petitioner's case on the fourth issue, upheld the demand for tax, interest and penalty aggregating Rs. 71,42,956, and directed payment within one month. The respondent attributed this inconsistency to an incorrect selection while generating the order on the portal and issued a Corrigendum dated 28.05.2024 clarifying that proceedings were dropped on three issues while the demand on the fourth survived.
The court held that an adjudication order cannot be divided into disconnected parts, but the same principle prevents the Portal Order from being read in isolation from the Annexure it expressly incorporates. The Annexure accompanied the original upload, was produced by the petitioner himself as part of Annexure P-1, and contained detailed reasons and quantification — it could not be treated as a standalone unsigned order requiring separate authentication when the digitally signed Portal Order expressly adopted it. On the Corrigendum, the court held it fell within Section 161 as the error was apparent on the face of the record — the composite order's own Annexure contradicted its portal recital — and the correction required no reconsideration of merits or enlargement of the demand. The third proviso to Section 161 (requiring natural justice for adverse rectification) did not apply because the Corrigendum did not withdraw any relief or enlarge any demand — it merely corrected an inconsistent recital to match the determination already made. The petitioner was granted four weeks to file an appeal under Section 107.
- 2026-juristway.com-2486-HC(Delhi)-GST | High Court of Delhi | W.P.(C) 7339/2024 | 08.09.2026