Facts of the Case
The petitioner, Tvl. Shri Ram Agencies (represented by its
Proprietor R. Rajakumar), is a registered taxpayer under the GST regime engaged
in distinct business operations, including a taxable recharge business and an
exempt charcoal business. For the Assessment Year 2020-21, the Respondent
authority (The Assistant Commissioner (ST)-1, Tuticorin) initiated assessment
proceedings alleging a substantial mismatch between the returns filed.
Specifically, the department alleged an excess availment of
Input Tax Credit (ITC) amounting to ₹20,49,702/-. This demand was framed
based on inconsistencies discovered across the portal data, specifically
contrasting forms GSTR-1, GSTR-2A, and the annual return GSTR-9. Additionally,
the department alleged that the petitioner failed to execute the mandatory reversal
of common credit under Rule 42 concerning its exempt charcoal business.
Treating the duplicated invoices appearing on the portal as unaccounted taxable
turnover, the Respondent passed an ex parte assessment order dated
01.09.2025 under Section 73, levying the tax demand along with applicable
interest and penalties. The petitioner approached the High Court via a Writ
Petition challenging the validity of this order.
Issues Involved
- Whether
the Respondent authority was justified in passing a cryptic, ex parte
assessment order solely relying on automated portal data discrepancies
without conducting a meaningful verification of the physical books and
external reconciliation statements submitted by the assessee?
- Whether
a technical portal glitch causing a duplication of GSTR-1 invoices
(pertaining to Tata Play Limited) can be automatically treated as
suppressed taxable turnover without cross-verifying the actual tax
discharge through Form GSTR-3B and subsequent credit note rectifications?
- Whether
the mechanical demand for a Rule 42 ITC reversal is legally sustainable
when the taxpayer maintains entirely separate accounts for taxable
operations and exempt supplies, thereby claiming no common input tax
credit?
- Whether
the impugned assessment order violated the fundamental principles of
natural justice, necessitating a remand for de novo adjudication under
equitable conditions.
Petitioner’s Arguments
- Technical
Glitch and Invoice Duplication: The learned counsel for the
petitioner, Mr. N. Sudalai Muthu, vehemently argued that the alleged
turnover discrepancy did not represent actual hidden revenue but was the
outcome of a systemic technical glitch on the GST portal. Invoices
relating to Tata Play Limited, which were already reported and properly
taxed during the period from April 2021 to July 2021, were automatically
duplicated by the portal into the GSTR-1 generated for August 2021.
- No
Loss to Revenue: It was emphasized that the actual tax
liability for the genuine invoices had already been fully discharged via
Form GSTR-3B filings. The accidental duplication was later rectified
systematically via the issuance of credit notes and captured transparently
during the annual reconciliation in Form GSTR-9; hence, there was zero
suppression of turnover or revenue loss to the government exchequer.
- Maintenance
of Separate Accounts: Regarding the Rule 42 allegations, the
petitioner asserted that they strictly maintained separate books of
accounts for the taxable recharge business and the exempt charcoal
business. Because no common ITC was ever claimed or utilized for the
exempt segment, the question of reversing credit under Rule 42 does not
arise.
- Failure
to Verify Records: The petitioner stated that they had
actively participated in the adjudication process by filing detailed
replies, invoice-wise breakdowns, sales registers, and ITC workings. They
argued that the respondent completely failed to apply their mind to these documents,
acting mechanically on the false assumption that portal data is final and
absolute.
Respondent’s Arguments
- Failure
to Utilize Portal Opportunities: The learned Government
Advocate, Mr. R. Parthiban, appearing on behalf of the revenue, submitted
that the department had provided ample opportunities to the taxpayer to
clarify the anomalies. Because the petitioner failed to adequately resolve
the system-generated mismatches within the statutory timeframe, the
authority was fully justified in finalizing the assessment ex parte.
- Sanctity
of GSTR-1 Data: The revenue contended that the primary basis
of the assessment was the data uploaded by the taxpayer/vendors themselves
in Form GSTR-1. Since the portal displayed clear mismatches between
GSTR-1, GSTR-2A, and GSTR-9, the department had to act on the official
figures to prevent potential revenue leakages. It was maintained that the
onus lay strictly on the assessee to prove the systemic error at the
initial stage.
Court Order / Findings
The Hon'ble Judge D. Bharatha Chakravarthy reviewed the
records and observed that the dispute centered heavily on technical portal
anomalies and specific accounting divisions that required meticulous factual
verification. The Court found that the respondent officer had mechanically
rejected the assessee’s explanations by blindly treating GSTR-1 portal figures
as final without validating the transaction history with the third-party entity
(Tata Play Limited) or analyzing the submitted credit notes.
Acknowledging that the High Court routinely extends
opportunities on equitable grounds to ensure a fair trial, the Court passed the
following directions:
- The
Writ Petition was allowed, and the impugned assessment order dated
01.09.2025 was set aside on the condition that the petitioner deposits 25%
of the disputed tax amount with the respondent within four weeks of
receiving the order copy.
- Upon
confirmation of the 25% pre-deposit, the entire matter stands officially
remanded back to the assessing officer for fresh consideration.
- The
petitioner is directed to appear before the respondent without fail,
presenting all supporting documentation, sales registers, and
reconciliation statements, which the respondent must evaluate afresh in
accordance with the law.
- Consequent
to the setting aside of the demand order, any bank account attachments
executed by the department pursuant to the impugned order were ordered to
be lifted immediately.
Important Clarification
This ruling reinforces a vital legal principle in contemporary
tax jurisprudence: GST Portal data entries are not absolute truths.
Automated system mismatches (GSTR-1 vs. 2A/3B/9) are merely flags for inquiry
and cannot serve as the sole conclusion for a tax demand under Section 73. If a
taxpayer produces corroborative evidence demonstrating portal duplication,
credit notes, or the segregation of accounts for exempt businesses, the tax
authorities are legally obligated to execute a substantive, manual verification
of the books rather than passing mechanical, cryptic ex parte orders.
Section Involved
- Primary
Section: Section 73 of the Central Goods and Services
Tax (CGST) Act, 2017 and the Tamil Nadu Goods and Services Tax (TNGST)
Act, 2017 (pertaining to the determination of tax not paid, short paid,
erroneously refunded, or Input Tax Credit wrongly availed or utilized for
reasons other than fraud, willful misstatement, or suppression of facts).
- Procedural
Provision: Article 226 of the Constitution of India
(Writ Jurisdiction for Certiorarified Mandamus).
- Rules Triggered: Rule 42 of the CGST/TNGST Rules, 2017 (Reversal of common Input Tax Credit on inputs and input services attributable to exempt supplies).
Link to download the order - https://mytaxexpert.co.in/uploads/1783061898_336compressed.pdf
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