Input Tax Credit claims require reconsideration where returns were filed before the statutory cut-off date.

An adjudication order rejecting Input Tax Credit was quashed in part because the claim had to be re-examined against the returns filed before the relevant cut-off date. The dispute arose from proceedings under Section 73(1) of the Karnataka GST Act, and the petitioner relied on returns filed before the date fixed by the later amendment and notification. As similar claims had been directed for reconsideration where returns were filed within the statutory timeline, the authority was required to fresh examine whether the conditions for ITC were satisfied on the basis of returns filed before 30.11.2021.

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Issues: Whether the adjudication order rejecting the petitioner's Input Tax Credit claim for the relevant period required to be quashed and the matter reconsidered in the light of the returns filed before the cut-off date.

Analysis: The impugned demand arose from proceedings initiated under Section 73(1) of the Karnataka Goods and Services Tax Act, 2017. The petitioner asserted that the relevant returns were filed before the stipulated cut-off date and before the date emerging from the subsequent amendment and notification relied upon. The record also reflected that similar claims had been directed to be reconsidered where the returns were filed within the relevant statutory timeline. In these circumstances, the existing adjudication could not be sustained without fresh examination of whether the petitioner satisfied the conditions for claiming Input Tax Credit.

Conclusion: The adjudication order was quashed to that extent and the authority was directed to reconsider and examine the petitioner's entitlement to claim Input Tax Credit on the basis of the returns filed before 30.11.2021.

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