Provisional GSTIN correction for wrong PAN upheld where the registration error was a verifiable administrative mistake.

A provisional GSTIN generated through the GST Network was found to contain an incorrect PAN, and the error was treated as an apparent administrative mistake attributable to the portal authorities. The Court held that, where the pre-GST change in proprietorship and related registration correction were verifiable from the assessing authority, the registration particulars required rectification rather than a fresh registration route. It further directed that invoices, declarations and returns bearing the wrong provisional GSTIN would stand corrected on a deemed basis, with the petitioner entitled to the consequential benefits flowing from that correction.

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Issues: Whether the provisional GSTIN generated for the petitioner was liable to be corrected to reflect the petitioner's PAN, and whether the consequential benefits flowing from such correction were required to be granted.

Analysis: The provisional GSTIN was generated through the GST Network on the basis of verification of the email address and mobile number submitted by the petitioner, and the middle ten characters ought to have reflected the PAN of the person who had become the proprietor before GST implementation. The wrong PAN appearing in the provisional GSTIN was attributable to the GST Network and constituted a mistake apparent from the record. The objection that the petitioner ought to have followed some other course for obtaining fresh registration was treated as hyper-technical. Once the change in proprietorship and the earlier VAT registration correction were verifiable from the assessing authority, the error required rectification. The Court also directed that, upon such verification, the invoices, declarations and returns containing the wrong provisional GSTIN would stand corrected on a deemed basis, and the petitioner would be entitled to the corresponding benefit already recognised in the related decision.

Conclusion: The provisional GSTIN was directed to be corrected in favour of the petitioner by substituting the petitioner's PAN, subject to verification of the amended proprietorship registration, with consequential reliefs flowing from that correction.

Final Conclusion: The writ petition succeeded and the petitioner obtained a mandatory direction for rectification of the GST registration particulars, together with ancillary consequential relief.

Ratio Decidendi: A provisional GST registration generated on the basis of verified particulars may be corrected where the wrong PAN is an apparent administrative error attributable to the portal authorities and the correction is supported by verifiable pre-GST change of proprietorship.

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