The Delhi High Court has permitted an exporter to rectify old GST filings from FY2017-18, emphasising that portal restrictions should not hinder legitimate corrections arising from customs amendments, highlighting a significant shift for early GST taxpayers.
The Delhi High Court has given an exporter the green light to clean up a set of old GST filings from FY2017-18, saying the tax department should not let portal limits block corrections that flow from earlier customs amendments. The ruling matters because it deals with a problem many early GST taxpayers faced: the paperwork was right, but the system would not always let the return match the paperwork.
According to the court, Shine Shipping Company had exported goods to a buyer in Hong Kong through three shipping bills in October and November 2017. The firm said the export value and IGST figures were entered incorrectly in those bills, even though tax had been paid on the actual transaction value and the export proceeds were realised. Customs later approved amendments under Section 149 of the Customs Act, but the electronic system did not allow those changes to be pushed through into the GST returns.
That left the company stuck between records that had already been corrected on the customs side and GST forms that still showed mismatches. An earlier Bench had already told the firm to approach the Delhi GST department and suggested that manual effect could be given if the portal could not handle the revision. In the latest hearing, the court said the issue was no longer about reopening the original customs relief, but about the knock-on GST corrections that should follow from it.
The Division Bench, comprising Justice Anil Kshetrapal and Justice Shail Jain, allowed rectification of the short reporting of Rs 38,17,280 in GSTR-3B, reconciliation of the mismatch with GSTR-2A, and consequential changes to GSTR-9 for 2017-18. The court also made clear that the department can still verify the corrections and carry out assessment or scrutiny under the law. For businesses, the takeaway is straightforward: where the facts support the claim and earlier proceedings were kept alive, technical filing limits may not be the last word, especially for GST-era mistakes made when the system was still bedding in.
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