Transitional SGST input tax credit refund requires proof that...

Transitional SGST input tax credit refund requires proof that the unutilised erstwhile-regime credit stood as an opening balance in the Electronic Credit Ledger on 1 July 2017. In the absence of the prescribed TRAN-1 declaration or other satisfactory evidence of that balance, the refund claim fails. Writ jurisdiction under Article 226 ordinarily cannot be used to revive a statutory challenge after the taxpayer's own default has allowed the appeal limitation to expire, particularly where the delay is inordinate. The writ petition was dismissed because the transitional credit was unsubstantiated and the statutory appellate remedy had become time-barred.