GST TRAN-1 portal failure can justify equitable relief to protect transitional credit and permit filing by alternative means.

Where a taxpayer is prevented from filing Form GST TRAN-1 within time because of portal-related technical failure, equitable relief may be granted to preserve the substantive right to carry forward transitional credit. The Court noted repeated attempts to upload the form, supporting material showing GST portal difficulties, and the practical compliance problems faced during GST implementation. Relying on similar cases, it held that the petitioner's request deserved consideration and that directions were warranted either to enable electronic filing by opening the portal or to accept the form manually.

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Issues: Whether the respondents could be directed to enable the petitioner to file Form GST TRAN-1 electronically through the portal or, alternatively, to accept the form manually where the petitioner claimed inability to file within time because of portal-related technical difficulties.

Analysis: The petitioner asserted repeated attempts to file Form GST TRAN-1 within the extended time and placed material showing that the return could not be uploaded because of technical problems on the GST portal. The Court noted the practical difficulties faced by assessees in the GST implementation phase and relied upon the approach adopted in similar cases, where relief had been granted when the portal failure prevented compliance. In that background, the petitioner's request was found deserving of consideration.

Conclusion: The issue was answered in favour of the petitioner, and directions were warranted to permit either electronic re-filing by opening the portal or acceptance of the form manually.

Ratio Decidendi: Where a taxpayer is prevented from filing transitional credit declarations due to portal-related technical failure, equitable relief may be granted to preserve the substantive entitlement to carry forward credit.

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