Can transitional credit through TRAN-1 and TRAN-2 be claim after expiry of due date i.e 27.12.2017?

TRAN-1 and TRAN-2 be claim

Case Title

Aarti Industries Ltd vs Union of India

Court

Gujarat High Court

Honorable Judges

Justice N.V Anjaria & Justice Bhargav D. Karia

Citation

2022 (8) GSTPanacea 158 HC Gujarat

C/SCA 1360/2022

Judgement Date

08-August-2022

Council for Petitioner

Jainish P Shah

Council for Respondent

 

The Gujarat High Court bench of Justice N.V Anjaria & Justice Bhargav D. Karia has held that the aforesaid decision of the Supreme Court shall govern the right of the parties accordingly GSTN is directed to open common portal for filing concerned forms for availing Transitional Credit through TRAN-1 and TRAN-2 for two months i.e. w.e.f. 01.09.2022 to 31.10.2022.

FACTS OF THE CASE

Between 6.7.2017 to 31.7.2017, the petitioner filed Form ER-1 Returns for the month of June, 2017 in respect of its nine manufacturing units. The Goods and Services Tax regime came into effect from 1.7.2017. The GST Tran-1 filed by the petitioner in respect of the nine manufacturing units and credit was received in the Electronic Credit Ledger. The petitioner, however, could not have credit of Educational Cess and Secondary and Higher Secondary Education Cess

 

Petitioner file petition to direct the respondents to transmit Rs. 43,73,628/- (Rupees Forty Three Lakhs Seventy Three Thousand Six Hundred and Twenty Eight only) towards unutilised accumulated CENVAT credit balance of the Education Cess and Secondary & Higher Education Cess by allowing the petitioners to manually file Form GST TRAN-1

To direct the respondents to credit Rs. 43,73,628/- (Rupees Forty Three Lakhs Seventy Three Thousand Six Hundred and Twenty Eight only) towards unutilised accumulated CENVAT credit balance of the Education Cess and Secondary & Higher Education Cess, directly in the Electronic Credit Ledger of the petitioner

Petitioner address that the issue involved and required to be addressed in this petition has been answered by the Apex Court in case of Union of India and anr vs. Filco Trade Centre Pvt. Ltd and anr in Special Leave to Appeal No. 32709–327010 of 2018 and another allied matters decided on 22.07.2020.

TRAN-1 and TRAN-2 be claim

COURT HELD

Considering the facts as recorded, held that he aforesaid decision of the Supreme Court shall govern the right of the parties

Goods and Service Tax Network (GSTN) is directed to open common portal for filing concerned forms for availing Transitional Credit through TRAN-1 and TRAN-2 for two months i.e. w.e.f. 01.09.2022 to 31.10.2022

The concerned officers are given 90 days thereafter to verify the veracity of the claim/transitional credit and pass appropriate orders thereon on merits after granting appropriate reasonable opportunity to the parties

The concerned officers are given 90 days thereafter to verify the veracity of the claim/transitional credit and pass appropriate orders thereon on merits after granting appropriate reasonable opportunity to the parties

TRAN-1 and TRAN-2 be claim

ANALYSIS OF THE JUDGEMENT

It goes without saying that the aforesaid decision of the Supreme Court shall govern the right of the parties

Considering the judgments of the High Courts on the then prevailing peculiar circumstances, any aggrieved registered assessee is directed to file the relevant form or revise the already filed form irrespective of whether the taxpayer has filed writ petition before the High Court or whether the case of the taxpayer has been decided by Information Technology Grievance Redressal Committee (ITGRC)

Goods and Service Tax Network (GSTN) is directed to open common portal for filing concerned forms for availing Transitional Credit through TRAN-1 and TRAN-2 for two months i.e. w.e.f. 01.09.2022 to 31.10.2022

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Aarti Industries Ltd

For Reference Visit:

Gujarat High Court