Belated input tax credit claims under retrospective Sections 16(5)-16(6) and GSTR-2A/GSTR-3B mismatch; orders quashed, reassessed

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....Belated claims for input tax credit are governed by retrospective Sections 16(5)16(6) introduced by Finance Act 2024, requiring re-adjudication on that legal point and resulting in reassessment on the merits in favour of the claimant where applicable. Discrepancies between GSTR-2A and GSTR-3B must be re-examined as factual issues by the original assessing authority after hearing the taxpayer, leading to quashing of impugned assessment orders and remittal for fresh adjudication. Interim relief is conditional: taxpayer must deposit 50% of disputed tax from electronic cash ledger within 30 days for suspension of bank attachment, failing which recovery proceeds as if relief denied.....