GST credit in a non-migrated registration may be transferred to the valid migrated account, with portal rectification directed.

Credit lying in a system-generated non-migrated GST registration created by technical or administrative error may be transferred to the taxpayer's valid migrated GST registration, so that the available credit remains usable in the correct account. Where the portal appears to have generated inactive or non-migrated GST numbers automatically, the authorities may also be directed to identify such entries and take corrective steps to rectify the system and report compliance. The operative focus is on preserving taxpayer credit and addressing portal-generated registration errors through administrative correction.

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Issues: (i) Whether the amount lying to the credit of the non-migrated GST number could be transferred to the migrated GST number of the petitioner; (ii) whether directions were warranted to identify and rectify non-migrated GST numbers automatically generated on the portal.

Issue (i): Whether the amount lying to the credit of the non-migrated GST number could be transferred to the migrated GST number of the petitioner.

Analysis: The petitioner had migrated only one registration into the GST regime, while the system generated another GST number without the petitioner's knowledge. The Court accepted the peculiar factual situation and found that the amount credited in the non-migrated account should be made available to the petitioner in its migrated GST registration.

Conclusion: The amount standing to the credit of the non-migrated GST number was directed to be transferred to the migrated GST number, in favour of the petitioner.

Issue (ii): Whether directions were warranted to identify and rectify non-migrated GST numbers automatically generated on the portal.

Analysis: The Court noted the existence of an apparent technical issue in the portal resulting in automatic generation of non-migrated GST numbers and active subsisting entries of such numbers. It directed the respondent authorities and the Board to examine the issue and take corrective steps.

Conclusion: Directions were issued to identify such non-migrated GST numbers and to take rectificatory steps within the stipulated time.

Final Conclusion: The petition succeeded on the substantive relief of transfer of credit, with additional administrative directions issued for portal rectification and compliance reporting.

Ratio Decidendi: Where a taxpayer's credit is found in a system-generated non-migrated GST registration created due to a technical/administrative error, the Court may direct transfer of such credit to the valid migrated GST registration and order corrective administrative action.

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