GST transitional credit cannot be denied where portal unavailability prevented timely filing of TRAN-II, manual filing may be permitted.

The GST transitional framework was intended to preserve accumulated credit under the earlier tax regime, and a rigid reading of the filing deadline should not defeat that substantive right where the taxpayer attempted timely compliance but the electronic utility was unavailable. In those circumstances, permitting manual filing of GST TRAN-II or reopening the portal for verification was warranted to avoid prejudice caused by technical inability and to protect transitional credit on stock held on the appointed date.

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Issues: Whether the petitioner was entitled to be permitted to file GST TRAN-II manually or through reopening of the portal so as to claim transitional credit on stock held on the appointed date, despite expiry of the prescribed time under the transitional rules.

Analysis: Transitional provisions under the GST regime were intended to protect credit accumulated under the earlier tax system. The petitioner had attempted to comply within time, but the electronic utility for filing the declaration was not made available within the relevant period. In such circumstances, the time prescription for filing the transitional form could not be applied so rigidly as to defeat the substantive right to transition credit. The relief sought was supported by the need to avoid prejudice caused by technical inability and to preserve the intended benefit of the transitional framework.

Conclusion: The petitioner was entitled to reopening of the form or acceptance of manual filing of GST TRAN-II for verification and grant of transitional credit.

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