Input tax credit denial may be reconsidered on limited verification of supplier return documents and supporting records.

An appellate order refusing input tax credit was directed to be revisited on a limited basis where the taxpayer produced supplier return documents said to support the claim. The Court held that authenticity could not be conclusively determined on the writ record and that fairness required an opportunity to place supporting material before the appellate authority. The reconsideration was confined to the input tax credit claim relating to the concerned supplier for the relevant period, and the authority was left free to verify genuineness and authenticity before passing a reasoned order.

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Issues: Whether the appellate order denying input tax credit required reconsideration in view of the supplier's return documents and whether the matter should be reopened for limited verification.

Analysis: The Court noted the petitioner's reliance on return filings said to have been made by the supplier for the relevant period and also recorded the State's fair submission that benefit could follow if such filing was established. As the authenticity of the documents could not be decided on the writ record, the Court found that the interests of justice required an opportunity to produce supporting documents before the appellate authority. The reconsideration was confined only to the input tax credit claim relating to the concerned supplier for the relevant period, with liberty to the authority to test genuineness and authenticity and then pass a reasoned order.

Outcome: The impugned order was directed to be revisited by the appellate authority on a limited basis, after the petitioner produces supporting documents.

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