Transitional Input Tax Credit preserved despite retrospective timing amendment, as timelines deemed directory and credit treated as vested right.
The Delhi High Court held that the Brand Equity reasoning survives a retrospective amendment inserting a time limit into the transitional GST provision. The Court found the delegated classification of timelines arbitrary and vague, treated transitional Input Tax Credit as a vested right protected under Article 300A, and concluded that procedural timelines are directory because no consequences for non-compliance are prescribed and timelines have been extended historically. (AI Summary)