Taxpayer's GST Challenge Dismissed: Insufficient Documentation and Non-Cooperation Invalidate Claims Under Section 74

The HC upheld the GST assessment order and rejected the petitioner's rectification application. The court found the petitioner failed to cooperate during assessment, did not adequately justify Input Tax Credit claims, and did not provide necessary reconciliation details despite multiple opportunities. The assessment order and rejection of rectification were deemed valid due to the petitioner's lack of substantive compliance with procedural requirements.

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Issues Involved:
The challenge to an order of assessment under the Goods and Services Tax Act, 2017 and the rejection of a rectification application under Section 161 of the Act.

Assessment Order Challenge:
The petitioner did not cooperate during the assessment process, despite receiving various notices including a show cause notice. The issue on merits pertains to the grant of Input Tax Credit (ITC). The petitioner failed to justify its claim of ITC despite being given opportunities to do so. The officer called for details of ITC category wise/tax type wise, which the petitioner did not provide adequately. The petitioner argued that there were no variations in its ITC claims, but failed to reconcile the differences between returns filed and auto-populated data.

Rectification Application Rejection:
The petitioner's application under Section 161 for rectification of errors was rejected as there was no material supplied that indicated any error apparent on record. The officer had granted multiple opportunities for the petitioner to provide necessary information for reconciliation, which was not complied with. The petitioner's argument that the Assessing Officer should have examined accompanying details without their submission was deemed unreasonable.

Conclusion:
The court dismissed the Writ Petitions and connected Miscellaneous Petitions due to the petitioner's lack of cooperation in the assessment process and failure to assist in providing necessary information. The Assessing Officer was not expected to rectify errors without the petitioner's cooperation, and hence the rejection of the rectification application was upheld.

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