Input Tax Credit re-credit cannot be denied for lack of portal functionality when entitlement is undisputed.

A taxpayer's accrued entitlement to re-credit of Input Tax Credit in the electronic credit ledger was held not to be defeated by the GST portal's lack of functionality for refund claims rejected after debit through DRC-03. The department did not dispute the entitlement; the only obstacle was the absence of a system-based option for re-credit in the relevant factual situation. The Court treated this procedural limitation as incapable of overriding a vested entitlement and indicated that manual intervention could be used to give effect to the re-credit. The practical effect was recognition of re-credit in the ledger despite the portal's technical limitation.

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Issues: Whether the petitioner was entitled to re-credit of Input Tax Credit in the electronic credit ledger through manual intervention despite the absence of portal functionality for refund claims rejected after debit through DRC-03.

Analysis: The entitlement to re-credit was not disputed by the department. The difficulty arose only because the GST portal did not provide a functionality for re-credit in the factual situation arising from refund claims made under the relevant category and debited through DRC-03. The Court treated the procedural or technical inability of the system as incapable of defeating the petitioner's accrued entitlement to re-credit, particularly where the department itself had acknowledged the claim and the absence of portal functionality was the only obstacle. Denial of re-credit in such circumstances would amount to withholding a vested entitlement on a purely technical ground.

Conclusion: The petitioner was entitled to re-credit of the refund amount in the electronic credit ledger through manual intervention.

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