Vishist Business Solutions Private Limited Vs Appellate Joint Commissioner of State Tax (ST) (Telangana High Court)
Telangana HC Allows Rectification Route for ITC Mismatch Due to GSTR-2A Discrepancy – Relief to M/s. Vishist Business Solutions (AY 2018-19)
Introduction
Input Tax Credit (ITC) mismatches between GSTR-2A and GSTR-3B have been one of the most litigated issues under GST, often arising due to supplier-side errors. Taxpayers frequently face demands despite having genuine transactions, simply because invoices were not timely reflected in returns.
In a pragmatic ruling dated 22.01.2026, the Telangana High Court provided relief to M/s. Vishist Business Solutions Pvt. Ltd., allowing it to seek rectification of the assessment order where ITC was denied due to mismatch. The judgment highlights that procedural lapses by suppliers should not unjustly burden recipients, especially when supporting evidence exists.
Case Background
The petitioner challenged:
- Order-in-Original dated 18.04.2024 passed under GST law
- Appellate Order dated 19.11.2025, affirming the demand
The dispute related to AY 2018-19, where:
- ITC was denied due to non-reconciliation between GSTR-3B and GSTR-2A
- Authorities relied on Section 16(2)(c) of the GST Act
- The petitioner failed to produce CA certificates / supplier confirmations as required under CBIC Circular dated 27.12.2022
However, later developments showed:
- Supplier had uploaded invoices belatedly in September 2019
- Tax liability was fully discharged by the supplier
- The invoices were eventually reflected in GSTR-2A
Key Legal Issue
