Input tax credit reconciliation: import and SEZ credits could not be denied solely on GSTR-3B versus GSTR-2A mismatch.

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....Input tax credit mismatch between GSTR-3B and GSTR-2A, in relation to import and SEZ procurements, did not by itself establish excess availment where GSTR-2A for the relevant period did not capture such credits by design. The HC noted that the petitioner had disclosed the procurements in GSTR-3B and later in GSTR-9, and that import credit was supported by the Bill of Entry; the demand, interest and penalty on this ground were set aside. On the remaining issues, including corporate guarantee, cross-charges, promotion expenses, merchant export rate, export refund, reverse charge on import of services and medical-consultation credit, the adjudication was found unsustainable for failure to consider the governing provisions, circulars, notifications and submissions, so those findings were remanded for fresh decision.....