Oasys Cybernetics Private Limited Vs State Tax Officer (Madras High Court)
Summary: The Madras High Court, in the case of Oasys Cybernetics Private Limited vs. State Tax Officer (W.P. No. 16224 of 2024, dated July 9, 2024), addressed a dispute where Input Tax Credit (ITC) reflected in GSTR-2A was not considered during the assessment process. The petitioner, M/s. Oasys Cybernetics, contested an adjudication order dated March 7, 2024, alleging the failure to acknowledge 11 bills of entry auto-populated in GSTR-2A. This oversight led to an erroneous tax demand of ₹77,59,284. The petitioner’s counsel argued that this discrepancy arose due to mismatched data from the GST Model-2 portal, which the petitioner could not access, and sought a reassessment. The court noted that the 11 bills of entry, corresponding to the disputed ITC, warranted reconsideration. While the tax department claimed compliance with natural justice by issuing notices and considering replies, the mismatch between ICEGATE data and the GSTR-2A records was deemed significant. To resolve the matter, the court set aside the impugned order on the condition that the petitioner remits ₹8,00,000 as part of the disputed tax demand within four weeks. Post-payment, the tax authority was instructed to conduct a fresh adjudication, providing the petitioner with a personal hearing and finalizing the revised order within three months. This decision underscores the importance of accurate ITC reconciliation in GST assessments and reinforces the obligation of tax authorities to thoroughly evaluate GSTR-2A records before confirming tax demands. The court’s directive aims to ensure fair assessment and compliance with principles of natural justice.
