Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Substantive entitlement to re-credit of input tax credit cannot be denied merely because the common portal lacks a corresponding functionality. The High Court noted that the department itself accepted that the taxpayer had sought re-credit after rejection of refund claims and had not pursued any further appeal; the only obstacle was the absence of an option to issue PMT-03 or restore the amount to the electronic credit ledger. Once entitlement to re-credit was undisputed, any procedural lapse was immaterial, and the Court directed restoration of the amount through manual intervention. The writ petition was allowed.
Substantive entitlement to re-credit of input tax credit cannot be denied merely because the common portal lacks a corresponding functionality. The High Court noted that the department itself accepted that the taxpayer had sought re-credit after rejection of refund claims and had not pursued any further appeal; the only obstacle was the absence of an option to issue PMT-03 or restore the amount to the electronic credit ledger. Once entitlement to re-credit was undisputed, any procedural lapse was immaterial, and the Court directed restoration of the amount through manual intervention. The writ petition was allowed.
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