Retrospective input tax credit entitlement cannot be denied merely for delayed rectification; procedural limits yield to substantive relief.

Retrospective insertion of Sections 16(5) and 16(6) was treated as creating a substantive entitlement to input tax credit, which could not be defeated solely because a rectification application was filed beyond the six-month period in Notification No. 22/2024. The limitation in the notification was regarded as procedural, and procedural stipulations were held not to override substantive relief. The rejection of the rectification application on limitation was therefore not sustained, and the matter was remitted for fresh consideration on merits after notice, including examination of entitlement and other statutory compliance.

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Issues: Whether the rectification application filed beyond the six-month period prescribed under Notification No. 22/2024 could be rejected when the assessee's entitlement to input tax credit had been subsequently recognised by Sections 16(5) and 16(6), and whether the rejected rectification application should be restored for fresh consideration on merits.

Analysis: The later insertion of Sections 16(5) and 16(6) with retrospective effect was treated as conferring a substantive entitlement which could not be defeated merely on account of delay in invoking the rectification mechanism under the notification. The time limit in Notification No. 22/2024 was treated as a procedural requirement, and procedural stipulations were held not to override substantive relief. The rectification application was therefore directed to be restored, with the respondent required to examine entitlement and other statutory compliance on merits after notice to the petitioner.

Conclusion: The rejection of the rectification application on limitation was not sustained, and the matter was remitted for fresh consideration on merits; the assessee obtained partial relief.

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