GSTR-3B correction of bona fide input tax credit entry error was permitted despite the bar on belated revision.

Correction of GSTR-3B returns was permitted where the taxpayer had made an inadvertent, bona fide wrong-column entry of eligible Input Tax Credit in the first GST year. The court treated the error as an accounting mistake rather than a claim for fresh or expanded credit, noting that the credit was otherwise available, no prejudice would be caused to the Revenue, and the GST credit chain would remain intact. The statutory bar on belated revision was therefore not applied mechanically on these facts, and Bharti Airtel was distinguished because it involved a different situation.

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Issues: Whether the petitioner was entitled to rectify its GSTR-3B returns for July 2017 and March 2018 and whether the prohibition against belated revision of returns barred such correction in the facts of the case.

Analysis: The corrections sought related to wrong-column entry of eligible Input Tax Credit in the first year of the GST regime, and the records showed that the mistake was inadvertent and bona fide. The disputed credit was otherwise available, and permitting correction would merely shift the credit from one head to another without causing prejudice to the Revenue or disturbing the GST credit chain. The Court held that the statutory bar relied upon by the Revenue could not be applied mechanically on these facts, and the decision in Bharti Airtel did not govern the present situation because the petitioner was not seeking a fresh or expanded credit, but only correction of an accounting error already reflected in the returns and supporting data.

Conclusion: The petitioner was entitled to permission to correct the GSTR-3B returns, and the Revenue was restrained from taking coercive steps on the show-cause notice until compliance with that direction.

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