Transition credit: administrative transfer to electronic credit ledgers urged to prevent time limit disputes.
Procedural rigidity over filing transitional credit declarations has produced conflicting High Court rulings and litigation; instead of insisting on strict compliance with time limits, authorities could have transferred amounts reported in returns up to the migration cutoff directly into taxpayers' Electronic Credit Ledgers, using available departmental data and administrative validation, thereby avoiding repeated retrospective amendments, special remedial rules, and protracted court disputes. (AI Summary)