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GST amnesty appeals should not be rejected solely because the prescribed cash component of a pre-deposit was debited through the electronic credit ledger rather than the electronic cash ledger, where portal glitches prevented the required cash-ledger debit. Such misallocation is a curable pre-deposit defect when the amount has otherwise been secured. The appellate authority must allow the taxpayer to rectify the cash-ledger component or rebalance the ledger debits, including re-credit of excess electronic credit ledger debit. Following rectification within the stipulated period, the first appeal must be admitted and decided on merits after hearing both sides.
GST amnesty appeals should not be rejected solely because the prescribed cash component of a pre-deposit was debited through the electronic credit ledger rather than the electronic cash ledger, where portal glitches prevented the required cash-ledger debit. Such misallocation is a curable pre-deposit defect when the amount has otherwise been secured. The appellate authority must allow the taxpayer to rectify the cash-ledger component or rebalance the ledger debits, including re-credit of excess electronic credit ledger debit. Following rectification within the stipulated period, the first appeal must be admitted and decided on merits after hearing both sides.
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