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Issues: Whether the petitioners could be denied transitional input tax credit and filing of TRAN-1 merely because the upload could not be completed before the cut-off date, despite an attempted login and alleged portal difficulty.
Analysis: The petitioners had migrated from the VAT regime to the GST regime and sought to carry forward eligible credit under the transition provisions governing transfer of credit. The system log showed that they had attempted to log into the portal within time. The inability to complete upload was treated as a procedural difficulty and not a sufficient ground to defeat the substantive entitlement to carry forward accrued credit. The Court also followed the view that transitional credit cannot be denied solely on procedural defects when the attempt to comply is established, and directed that the authorities may still verify the genuineness of the claim.
Conclusion: The petitioners were entitled to file TRAN-1 either electronically or manually, and the denial of transitional credit on the ground of non-filing before the cut-off date was not sustainable.
Ratio Decidendi: Transitional input tax credit cannot be denied merely for procedural non-compliance where the assessee has timely attempted to file and the claim remains subject to verification.
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