Gulf Ashley Motor Limited Through Aryamishra Prabhakar Deo Mukul vs. Goods And Services Tax Council Through Its Secretary

Held

The Court held that the GST authorities, including the Nodal Officer, were obligated to ensure that the petitioner's Form TRAN-I was accepted and scrutinized. The Court acknowledged the technical glitch preventing online acceptance. Therefore, it directed the Nodal Officer to ensure the Form TRAN-I was accepted on the portal within the due date. If the portal continued to be inaccessible due to the glitch, the form was to be accepted manually. Following acceptance, the GST authorities were to conduct the necessary scrutiny to determine the acceptability of the petitioner's ITC claim, taking all necessary steps in accordance with the law and within the stipulated due date. The core principle established is that technical glitches should not prevent taxpayers from availing their legitimate claims, and authorities must provide a mechanism for manual acceptance and scrutiny in such circumstances.

Facts

The petitioner, Gulf Ashley Motor Limited, sought to claim input tax credit (ITC) under the Goods and Services Tax (GST) regime. However, they were unable to file Form TRAN-I on the GST portal due to a nationwide technical glitch. The petitioner reported this issue, and the Principal Commissioner, GST & CX, Ranchi, forwarded their application to the Nodal Officer on March 27, 2019. Despite these efforts, the Form TRAN-I had not been accepted by the GST portal due to the ongoing technical issue. The court was not concerned with the petitioner's entitlement to the ITC itself, but rather with the acceptance and scrutiny of their Form TRAN-I by the GST authorities.

Key Issues

1. Whether the GST authorities are required to accept and scrutinize the Form TRAN-I submitted by the petitioner, despite the technical glitch on the GST portal? (Question of law and fact, concerning the procedural obligations of GST authorities). Contentions: Petitioner: Argued that due to a technical glitch on the GST portal, they were unable to file Form TRAN-I, and therefore, the authorities should be directed to accept and process their claim. They relied on the fact that the issue was reported and forwarded to the Nodal Officer. Revenue/State: Did not record any specific arguments against the petitioner's claim for acceptance of Form TRAN-I. Their counsel appeared and heard the court's directions.