Input tax credit entitlement after registration cancellation hinges on voluntary DRC-03 payment and portal acceptance enabling claim.
Where GST registration is cancelled and revocation is pending, a taxpayer may make voluntary tax and interest payments via Form GST DRC-03 and, if such payments and disclosures are accepted on the portal and recorded by the proper officer (including issuance of DRC-04), claim input tax credit subject to possession of valid invoices, disclosure in books, procedural return compliance, and the unresolved legal tension between Section 16(2) and Section 16(4) of the Act. (AI Summary)

e-way bill expiry does not justify suppression allegation by a tax officer when e-invoice and prior verification exist
Expiry of an e-way bill alone does not establish suppression where goods are accompanied by an e-invoice and the movement was pre-notified to authorities. The portal's extension mechanism is limited and available only to the e-way bill issuer within prescribed time windows; duplicate e-way bills for the same invoice and GSTIN are not permitted. Prior verification by a tax officer that allowed onward movement reduces the tenability of later suppression allegations based solely on lapse of validity. (AI Summary)

Eligible input cap restricts credit to invoices reflected in GSTR-2A, altering recipient GST credit availability.
Notification No. 49/2019 amended CGST rules to make recipients' entitlement to eligible input credit dependent on invoices or debit notes uploaded by suppliers and reflected in the recipient's Form GSTR-2A, with an additional capped entitlement not exceeding twenty percent of such reflected entries. Practical consequences include disputes where suppliers file quarterly, amend past returns, or upload belatedly; the rule was effectively applied to CGST and IGST credits pending state-level SGST rule amendments. A suggested compliance tactic is to claim credit in Form GSTR-3B and reverse any excess within the same return to mitigate interest exposure. (AI Summary)

Amnesty scheme under GST enables revocation applications for registrations cancelled via portal to reclaim missed input tax.
Amnesty permits taxpayers whose registrations were cancelled-often due to electronic portal or e mail service issues-to apply for revocation of cancellation and restoration of original registration by filing an Application for Revocation of Cancellation of Registration in Form GST REG 21 within the extended period, enabling reclamation of missed input tax credits while remaining subject to other statutory provisions and procedural eligibility. (AI Summary)

Reversal of input tax credit requires reversal and may attract interest where payment to supplier is not made within the deadline.
Reversal of input tax credit is required when a recipient does not pay the supplier within the 180 day period; the recipient must add the amount to output tax liability and discharge the attendant interest under the GST statutory regime. Although the GST Council recommended waiving interest, no implementing notification has been issued, and judicial commentary treating recommendations as not self executing supports recovery of interest. In audit situations where the taxpayer disputes interest but has not reversed credit, the auditor must qualify the opinion. (AI Summary)

GSTR-2A reliability questioned: not conclusive proof of supplier compliance; recipient may face joint liability if supplier defaults.
An entry in a recipient's GSTR-2A is not conclusive proof that the supplier discharged GST because GSTR-3B is not auto-populated from GSTR-1, filing discrepancies can occur, and suppliers may file GSTR-1 without GSTR-3B. If a recipient availed input tax credit on such an entry and the supplier did not discharge the tax, the recipient can be held jointly and severally liable for the unpaid tax and may be liable to a demand from revenue authorities under the cited central GST amendment. (AI Summary)

Interest on GST liabilities remains payable on full tax due despite amounts held in the electronic cash ledger.
When tax is paid into the electronic cash ledger but GSTR-3B remains unfiled, interest is to be computed on the taxpayer's full tax liability because ledger balances are subject to conditional utilisation and withdrawal under Sec 49(3) read with Rule 61; CBIC guidance corroborates that ledger credit does not automatically relieve the running interest obligation unless statutory amendment or rules provide otherwise. (AI Summary)

GST migration mandatory: provisional enrolment and data submission required, with compliance risks for non submission.
The author asserts that GST migration enrolment is a mandatory administrative obligation for all dealers registered under State commercial tax regimes, requiring submission of entity information (constitution, premises, directors, authorised persons). Submission is provisional and not conclusive of statutory liability, but non compliance with data requests under existing commercial tax provisions may attract departmental action or penalty. Practical issues include inability of unregistered dealers to enrol and questions about penalties or surrender of provisional registrations while the GST statute remains in draft form. (AI Summary)