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Input tax credit denial based solely on a GSTR-2A/GSTR-3B...

Input tax credit mismatch requires transaction-level verification; demands must remain within show-cause notice and applicable verification periods.

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GST September 7, 2026 Case Laws AT
Input tax credit denial based solely on a GSTR-2A/GSTR-3B mismatch requires transaction-level verification of reconciliations, invoices, records and supplier-tax-payment conditions; a mismatch alone does not establish ineligibility. Section 16(2)(aa) does not apply to the disputed period, while Rule 36(4) must be applied as operative during each relevant portion. Tax demands must remain within the grounds and tax heads proposed in the show-cause notice, supported by a reasoned computation and factual basis. The CBIC ITC-verification mechanism applies only from April 2019 to 8 October 2019, requiring separate examination of later periods under the applicable substantive provisions.

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Acts Income Tax