GST Portal To Be Opened For GSTR-1 Rectification

Case Details: Ambica Auto Sales and Service vs. Union Bank of India - [2026] 182 taxmann.com 434 (Gujarat)

Judiciary and Counsel Details

A.S. Supehia & Pranav Trivedi, JJ.
Uchit N Sheth for the Petitioner.
CB Gupta for the Respondent.

Facts of the Case

The petitioner contested the denial of rectification of Form GSTR-1 and Form GSTR-3B despite an ITC mismatch arising from portal-related errors. It availed ITC on vendor invoices, and vendors issued credit notes for post-sale discounts. The portal matched only credit notes and ignored debit notes, and the petitioner reported the discount in the wrong field, causing a mismatch in Form GSTR-2A. It was submitted that there was no loss of revenue, and the petitioner requested that the portal be opened for rectification or manual correction be allowed. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that there was no revenue loss, as the tax paid on debit notes exceeded the proposed ITC reversal, and the error was confined to reporting rather than liability. It was noted that the Department showed no variance in actual tax due. The Court directed the jurisdictional officer under CGST to open the portal to enable rectification of Form GSTR-1 and Form GSTR-3B under Section 39 of the CGST Act and the Gujarat GST Act, and in case the portal was not opened, manual rectification was to be accepted. Consequently, the impugned order was quashed.