https://www.taxtmi.com/caselaws?id=785138 Rule 39(1)(a) of the CGST Rules, insofar as it required month-wise distribution of input tax credit before 1 April 2025, imposed a substantive time-forfeiture condition not found in Section 20 of the CGST Act. Section 20 permitted rules on the manner and conditions of distribution, but did not authorise extinguishment of vested credit through a mandatory timeline. Audit finalisation without an adequate opportunity to address spot memos and audit objections breached natural justice. Extended limitation based on suppression was unavailable where periodic portal disclosures showed no concealment. Writ jurisdiction remained available for a vires challenge and manifest procedural unfairness. The time-forfeiture requirement and consequential departmental action were set aside. en-us Tue, 30 Dec 2025 00:00:00 +0530 Thu, 15 Jan 2026 16:24:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785138 Rule 39(1)(a) of the CGST Rules, insofar as it required month-wise distribution of input tax credit before 1 April 2025, imposed a substantive time-forfeiture condition not found in Section 20 of the CGST Act. Section 20 permitted rules on the manner and conditions of distribution, but did not authorise extinguishment of vested credit through a mandatory timeline. Audit finalisation without an adequate opportunity to address spot memos and audit objections breached natural justice. Extended limitation based on suppression was unavailable where periodic portal disclosures showed no concealment. Writ jurisdiction remained available for a vires challenge and manifest procedural unfairness. The time-forfeiture requirement and consequential departmental action were set aside. Case-Laws GST Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785138