Transitional GST credit rectification must follow prescribed procedure with a hearing before coercive demand action proceeds.

A request for rectification of GST TRAN forms relating to transitional credit must be considered under the prescribed procedure, with an opportunity of hearing where required. The authority was directed to process the rectification request in terms of the applicable circular and GST network procedure, while the Court declined to decide the merits of whether the error was normal, intentional, or bona fide. Principles of natural justice must be observed before coercive action is taken on the disputed demand, and the impugned show cause notice was kept in abeyance until that decision is made.

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Issues: Whether the petitioners' request for rectification of the TRAN forms relating to transitional GST credit had to be processed under the prescribed procedure with an opportunity of hearing, and whether the impugned show cause notice deserved to be kept in abeyance till such decision was taken.

Analysis: The petitioners had already sought rectification of the mistake in the TRAN forms. In exercise of jurisdiction under Article 226, the Court declined to decide whether the credit claim represented a normal credit claim, an intentional error, or a bona fide mistake. Instead, it directed the competent authority to consider the rectification request, and if necessary, to hear the petitioners or their before forwarding the matter through the GST network in terms of the circular and prescribed procedure. The Court also noted that the principles of natural justice had to be followed before any coercive action was taken on the disputed demand.

Conclusion: The rectification request was directed to be processed in accordance with the prescribed procedure with hearing, and the show cause notice was kept in abeyance until a decision was taken.

Final Conclusion: The writ petitions were disposed of with interim procedural protection to the petitioners and without adjudicating the merits of the transitional credit dispute.

Ratio Decidendi: Where a taxpayer seeks rectification of a GST transitional credit mistake, the authority must consider the request under the prescribed procedure after affording a hearing, and coercive action on the disputed demand should await that decision.

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