Transitional GST credit preserved despite filing delay, with Form TRAN-I relief and claim verification permitted.

Transitional input tax credit under the pre-GST regime was treated as a protected and vested entitlement, and the time restriction in Rule 117(1A) of the Haryana GST Rules, 2017 was read in light of fairness under Article 14 and property protection under Article 300A. The Court did not strike down the rule, but it accepted that repeated extensions and technical migration issues could not defeat the taxpayer's substantive credit claim. The petitioner was therefore permitted to upload Form TRAN-I and, if necessary, to avail the corresponding credit in GSTR-3B, subject to verification of the claim's genuineness.

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Issues: Whether the petitioner was entitled to be permitted to upload Form TRAN-I and carry forward transitional credit despite expiry of the prescribed time limit, and whether the restriction in Rule 117(1A) of the Haryana GST Rules, 2017 could be applied to defeat that right.

Analysis: The petition was decided in the backdrop of earlier decisions holding that taxpayers should not be denied transitional credit merely because of technical difficulties in filing Form TRAN-I within time. The Court treated the credit accumulated under the pre-GST regime as a protected and vested entitlement and noted that repeated extensions granted by the authorities themselves reflected the practical difficulties faced by assessees in migrating to the GST electronic framework. The restriction was viewed in light of the constitutional mandate of fairness under Article 14 and the protection of property under Article 300A. On that reasoning, the Court declined to strike down the rule but held that the petitioner could not be deprived of the benefit of carrying forward the credit.

Conclusion: The petitioner was entitled to upload TRAN-I and, failing that, to avail the corresponding input tax credit in GSTR-3B, with the respondents retaining liberty to verify the genuineness of the claim.

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