GST transitional credit revision cannot be compelled beyond the statutory window for revised FORM GST TRAN-1.

Rule 120-A permits revision of FORM GST TRAN-1 only within the prescribed period, or within a further period extended by the Commissioner, and this power must be read with Rule 117, which limits filing of the transitional declaration and allows extension only up to ninety days on the Council's recommendation. A construction allowing indefinite revision would defeat the statutory scheme governing transitional credit under Section 140(3). On that basis, no mandamus could be issued to compel filing or acceptance of a revised TRAN-1 beyond the statutory window, and the requested extension was declined.

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Issues: Whether a writ of mandamus could be issued to permit filing or acceptance of a revised FORM GST TRAN-1 beyond the period prescribed under the Uttar Pradesh Goods and Services Tax Rules, 2017.

Analysis: Rule 120-A permits revision of a declaration in FORM GST TRAN-1 only within the period specified in the relevant rules or within such further period as may be extended by the Commissioner. That enabling power must be read with Rule 117, which confines the period for filing the declaration and allows extension only up to a further ninety days on the recommendations of the Council. A construction that permits an unlimited or indefinite extension for revision would defeat the statutory scheme and the legislative intent governing transitional credit. The request for transitional credit under Section 140(3) was therefore outside the permissible statutory window for judicially compelled extension.

Conclusion: No mandamus could be granted to allow filing or acceptance of a revised FORM GST TRAN-1 beyond the statutory period, and the relief sought was declined.

Final Conclusion: The petition was not entertained on merits in favour of the claimed extension, though the Council was left free to consider the petitioner's request in accordance with law.

Ratio Decidendi: A court cannot compel acceptance of a revised GST transitional declaration where the governing rules confine revision and extension to a limited statutory period and do not permit an indefinite enlargement of time.

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