Shri Kasturiji Sir,
Please allow me to make one more effort for presenting how Section 16(2) overrides other provisions of Section 16. As Section 16 has undergone the four amendments the provision effective from 01.01.2021 is discussed here.
At the very outset, the provisions of Section 16(2) which put the conditions (indicative) is stated below:-
(a) he is in possession of Invoice/debit note issued by the supplier
(b) he has received goods and/or services
(c) Tax charged by the supplier has been actually paid to the government account.
(d) he has furnished the return under Section 39
And the credit will be credited to the credit ledger (on provisional basis) on filing the return GSTR-3B, we can say that credit is availed (taken).
Now coming to sub-section (1) of section 16, where it is stated that every registered person is entitled (allowed) to take the credit of tax charged by the supplier, here no documentary evidence is mentioned therefore, overriding effect of 16(2) will come into play and registered person is bound to fulfill the condition stipulated therein, i.e., possession of Invoice, received goods and/or services etc. and all the provisions of 16(2) is applicable. If the documents do not satisfy the provisions of section 16(2), registered person is required to reverse the ITC in their GSTR-3B return.
For sub-section 3 of Section 16, wherein it is stated that in case of Capital goods (refer definition of Capital goods), which are capitalized in the book of accounts, as no documentary evidence for availing credit is stipulated, but for this purpose the provisions of Section 16(2) i.e., he is possession of Invoice/ debit note will be applicable, on satisfying the same, if ITC is availed the depreciation on the said capital goods cannot be claimed with IT department, in order to restrict double benefits. Hence, after satisfying provisions of Section 16(2) provisions of Section 16(3) will come into play as an additional condition.
For sub-section (4) of Section 16, states for the time limit for availing credit, as we know there cannot be limitless, if no time limit is mentioned, the act of limitation would be applicable. So, for any credit availed after satisfying the provisions of Section 16(2), if the Invoices which are older than the time limit prescribed in section 16(4) will be applicable.
Although Section 16(1), (3) and (4) are independent, but conjoint reading with Section 16(2) is mandatory for harmonizing with the other provisions of section 16 (applying the rule of interpretation).
For all the above, the credit will be credit to the credit ledger of the assessee on provisional basis and which can be either reversed if the conditions stipulated under Section 16(2) are not satisfied and also as per the other provisions such as Section 17(5).
As per above, we can conclude that Section 16(2) is having the overriding effect, for documentary evidence, for availing ITC.
There are other provisions such as Suo moto registration or cancellation of registration, audit, investigation, scrutiny etc. where the benefit available to the assessee should be extended by the department and overriding effect of Section 16(2) may play an important role.
This is the best of all I have.
Thanks,
With Due Regards.
TaxTMI 
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