Input tax credit claims require proof of genuine purchases and actual movement of goods; deficient findings warranted fresh adjudication.

Input tax credit under the Karnataka Value Added Tax Act, 2003 depends on the purchasing dealer discharging the burden of proof by reliable evidence of a genuine transaction and actual movement of goods. The court noted that the authorities below relied mainly on the selling dealers' NIL returns or missing turnover details, without properly applying the standard requiring supporting material such as dealer identity, vehicle particulars, freight details, delivery acknowledgment, tax invoices and payment records. Because the existing findings did not align with that burden-of-proof framework, the revisional order could not stand and the matter required fresh adjudication by the Assessing Authority.

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Issues: Whether the revisional interference with the appellate order denying input tax credit was sustainable, and whether the matter required re-adjudication in light of the burden of proof under Section 70 of the Karnataka Value Added Tax Act, 2003.

Analysis: The dispute turned on discharge of the burden under Section 70 of the Karnataka Value Added Tax Act, 2003 in relation to input tax credit claims. The reassessment authorities and the revisional authority proceeded on the basis that the selling dealers had filed NIL returns or not uploaded turnover details, and that the assessee had to establish genuineness of the purchases and actual physical movement of goods. The Court noted that the governing standard requires the purchasing dealer to prove the transaction with supporting material such as the identity of the selling dealer, vehicle details, freight particulars, acknowledgment of delivery, tax invoices and payment particulars, and that the findings recorded by the authorities below were not aligned with that standard as explained by the Supreme Court.

Conclusion: The revisional order could not be finally sustained on the existing record, and the matter had to be sent back to the Assessing Authority for fresh adjudication of the input tax credit claim in accordance with the burden of proof under Section 70 of the Karnataka Value Added Tax Act, 2003.

Ratio Decidendi: A claim for input tax credit under the Karnataka Value Added Tax Act, 2003 is sustainable only when the purchasing dealer establishes the genuineness of the transaction and the actual movement of goods by reliable supporting evidence; where the record does not reflect application of that standard, re-adjudication is warranted.

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