Input tax credit reversal cannot rest solely on supplier cancellation without evaluating purchaser evidence and allowing further substantiation.

Input tax credit eligibility requires the claimant to establish that supplies were genuine, but the assessing authority must properly consider documentary evidence including bank statements, tax invoices, e-way bills, ledger extracts, and GSTR-2A and GSTR-2B records. If that material is inadequate, the claimant must receive a reasonable opportunity to provide further evidence. Reversal cannot rest solely on a supplier's subsequent treatment as non-existent, particularly where the notice invoked Section 73 but the order proceeded under Section 74. The assessment therefore requires fresh consideration after granting reasonable opportunity.

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Issues: Whether reversal of input tax credit could be sustained solely because the supplier was subsequently treated as non-existent, without due consideration of the purchaser's documentary evidence.

Analysis: The burden to establish eligibility for input tax credit rests on the claimant, and the assessing authority was entitled to seek evidence that the supplies were genuine. The claimant had produced bank statements, tax invoices, e-way bills, ledger extracts and GSTR-2A and GSTR-2B records. Such material required due consideration; if it was insufficient, a reasonable opportunity to furnish further evidence was required. Confirmation solely on the supplier's subsequent cancellation as non-existent was untenable, particularly where the notice referred to Section 73 while the order was made under Section 74.

Conclusion: The input tax credit reversal could not be sustained on the stated basis; the assessment required fresh consideration after affording reasonable opportunity.

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