2026 (5) TMI 1800

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..... 2. In W.P.No.14839 of 2026, the petitioner has challenged the impugned Order-in-Original No.01/2024-25-GST (Supdt) dated 22.04.2024. The impugned order has been passed pursuant to the proposal set out in the Show Cause Notice, and the same has been confirmed after considering the petitioner's reply dated 05.02.2024. 3. The petitioner was issued Show Cause Notice No. 14/2023 dated 19.10.2023, wherein it was alleged that Input Tax Credit had been availed belatedly for the tax periods 2018-2019 and 2019-2020, beyond the limitation prescribed under Section 16(4). Thereafter, the impugned order came to be passed on 22.04.2024. Subsequently, in the light of the statutory intervention under Sections 16(5) and 16(6) inserted vide Finance (N....

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....passed. The said order has been impugned in W.P.14841 of 2026, whereby the application filed by the petitioner on 24.11.2025, seeking rectification of the order dated 22.04.2024, has been rejected with the following observations:- "6. In view of the forgoing, it is prima facie observed that the rectification sought by the tax payer under Notification No.22/2024 dated 08.10.2024, in respect of OIO Reference No.ZD3304242434998 dated 30.04.2024, and filed on 24.11.2025, has been submitted beyound that prescribed time limit of six months from the date of issuance of the said Notification. Accordingly, in light of the facts discussed above, the rectification application filed by the taxpayer under Section 148 of the CGST/TNGST Act, 2017....