Transitional GST credit cannot be denied for bona fide TRAN-1 filing delays caused by technical glitches and procedural failure.

Transitional input tax credit under GST should not be defeated solely by procedural delay where the assessee made bona fide efforts to file TRAN-1, including attempted electronic filing and manual submission after technical failure. The Court treated the filing deadline as procedural in character and relied on the Government's grievance mechanism for genuine TRAN-1 difficulties. It directed the authorities either to enable electronic filing or accept the manual TRAN-1 and process the credit if otherwise eligible in law.

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Issues: Whether the petitioner was entitled to relief for filing TRAN-1 beyond the prescribed time on account of technical glitches and genuine efforts to submit the form, and whether the authorities could be directed to enable electronic filing or accept the manual TRAN-1 for processing of transitional credit.

Analysis: The petitioner had attempted to file TRAN-1 electronically within the transition period and also made a manual submission when the online process failed. The Court noted that the Government circular recognised genuine grievances in TRAN-1 filing and provided a mechanism through Nodal Officers for struggling filers. It further held that GST is intended to ensure a seamless flow of eligible tax credits and that the due date for claiming transitional credit is procedural in character. Since the petitioner had made bona fide efforts and the credit claimed was part of the GST transition, denial on a purely procedural ground was not justified.

Conclusion: The petitioner was entitled to relief, and the respondents were directed either to open the portal for electronic filing of TRAN-1 or to accept the manually filed TRAN-1 and process the input credit if otherwise eligible in law.

Final Conclusion: The writ petition succeeded with directions protecting the petitioner's transitional credit claim, though the order was stated not to operate as a precedent.

Ratio Decidendi: Transitional input tax credit cannot be defeated solely on procedural delay where the assessee shows bona fide attempts to comply and the claim is otherwise legally eligible.

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