Input tax credit denial must be reconsidered when later amendment extends the claim period under the GST law.

Denial of input tax credit under the time restriction in Section 16(4) could not stand where the impugned order failed to consider the later inserted Section 16(5), which extended the claim period for the specified financial years. The High Court noted that the petitioner's entitlement had to be examined in light of the amended provision, and the authority was required to reconsider the claim after hearing the petitioner. The impugned order was therefore set aside to the extent of the denial of input tax credit, and fresh orders were directed on reconsideration.

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Issues: Whether the denial of input tax credit under Section 16(4) could stand without considering the effect of Section 16(5) and whether the order was liable to be set aside for fresh consideration.

Analysis: The claim for input tax credit for the relevant financial year was rejected by reference to the time restriction under Section 16(4). The later insertion of Section 16(5), which extended the time limit for claiming input tax credit for the specified financial years, was not considered in the impugned order. The entitlement claimed by the petitioner therefore required examination in the light of Section 16(5), and the matter called for reconsideration after hearing the petitioner.

Conclusion: The denial of input tax credit could not be sustained as made, and the matter had to be reconsidered by the competent authority after taking note of Section 16(5).

Final Conclusion: The writ petition succeeded, the impugned order was set aside to the extent of the denial of input tax credit, and fresh orders were directed to be passed after hearing the petitioner.

Ratio Decidendi: Where an order denying input tax credit does not consider an applicable extended time limit introduced by later statutory amendment, the denial is liable to be set aside for reconsideration in accordance with the amended provision.

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