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    <title>2026 (5) TMI 1800 - MADRAS HIGH COURT</title>
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    <description>Retrospective insertion of Sections 16(5) and 16(6) was treated as creating a substantive entitlement to input tax credit, which could not be defeated solely because a rectification application was filed beyond the six-month period in Notification No. 22/2024. The limitation in the notification was regarded as procedural, and procedural stipulations were held not to override substantive relief. The rejection of the rectification application on limitation was therefore not sustained, and the matter was remitted for fresh consideration on merits after notice, including examination of entitlement and other statutory compliance.</description>
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