The
petitioners, Sanchita Kundu & Another, approached the Calcutta High
Court by filing writ petitions challenging the action of the GST authorities
whereby the benefit of Input Tax Credit (ITC) was denied through an
order dated 27 December 2021. The denial was premised on the ground that
the GST registrations of the suppliers from whom the petitioners had purchased
goods were cancelled retrospectively, covering the relevant transaction period.
Consequential proceedings under Section 79(1)(c) of the West Bengal GST Act,
initiated through orders dated 29 March 2022 and 30 March 2022,
were also challenged.
The
petitioners contended that the transactions in question were genuine and duly
supported by statutory documents. It was asserted that, at the time of entering
into the transactions, the suppliers were reflected as valid registered taxable
persons on the GST portal. The petitioners submitted that they had exercised
due diligence to the extent reasonably possible under the law and that payments
towards the purchase consideration and applicable GST were made through banking
channels. All purchase invoices were duly reflected in GSTR-2A, forming
part of official records.
It was
further argued that the petitioners could not be penalised merely because,
subsequent to the transactions, the department concluded that the suppliers
were fake or bogus, unless the authorities were able to establish, with cogent
material, any collusion between the petitioners and the suppliers. Reliance was
placed on the earlier decision of the Calcutta High Court in M/s LGW Industries
Limited & Ors. v. Union of India & Ors.
Upon
consideration of the facts and submissions, the High Court observed that,
without proper verification, it could not be concluded that the petitioners had
failed to comply with their statutory obligations. The Court held that denial
of ITC without examining the genuineness of transactions, payment of tax,
timing of cancellation of supplier registration, and compliance with due
diligence requirements was unsustainable.
Accordingly,
the impugned adjudication orders were set aside, and the matter was remanded to
the concerned authorities for fresh consideration. The authorities were
directed to examine the relevant documents, verify whether payments including
GST were actually made, ascertain whether the transactions occurred prior to
cancellation of the suppliers’ registrations, and consider applicable judicial
precedents. The petitioners were to be afforded an effective opportunity of
hearing, and a reasoned and speaking order was directed to be passed within
eight weeks.
Consequently,
the writ petitions were disposed of in terms of the above directions, and all
consequential recovery proceedings were also quashed.
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