Judicial Reading Down to Safeguard Bona Fide Purchasers under Section 16(2)(c) of CGST Act.
Under the GST law, Section 16(1) allows a registered person to claim Input Tax Credit (ITC). However, this right is not automatic. Section 16(2) clearly states that ITC can be claimed only if certain conditions are fulfilled. These conditions are mandatory and must all be satisfied. Even if a person is otherwise eligible for ITC, failure to meet any of the requirements of Section 16(2) will result in denial of ITC.
Among the various conditions prescribed for claiming ITC, Section 16(2)(c) of the CGST Act, 2017 is an important provision. It requires that the tax charged on the supply must be actually paid to the Government before a registered person can claim ITC.
Section 16(2)(c) of the CGST Act, 2017 may be read as under-
“(c) subject to the provisions of section 41, the tax charged in respect of such supply has been actually paid to the Government, either in cash or through utilisation of input tax credit admissible in respect of the said supply; and”
Section 16(2)(c) of the CGST Act provides that a registered person cannot avail ITC on a supply of goods or services if the tax charged on such supply has not been actually paid to the Government, either in cash or through utilisation of admissible ITC.
In other words, ITC is available to the recipient only when the supplier has discharged the tax liability. This requirement effectively places a burden on the recipient to ensure that the supplier has complied with their tax payment obligations, an issue that has led to considerable debate and extensive litigation under the GST regime.
The condition under Section 16(2)(c) has been controversial because even an honest buyer and genuine buyer, who has paid the full tax amount to the seller, may be denied Input Tax Credit if the seller fails to deposit that tax with the Government. This provision makes the availability of ITC to the buyer dependent on the supplier’s compliance in paying tax, even though the buyer may have already paid the full tax amount to the supplier. As a result, genuine and bona fide purchasers may be denied ITC due to the supplier’s default, leading to widespread litigation and debate. The responsibility of proving eligibility for ITC lies with the buyer. Therefore, businesses must closely monitor their suppliers and regularly match their records to ensure that taxes are properly paid.
The constitutional validity of Section 16(2)(c) has been challenged before several High Courts across the country. However, courts such as the Kerala, Patna, Andhra Pradesh and Madras High Courts have generally upheld this provision. They have held that Input Tax Credit is not an absolute right but a statutory benefit, which can be granted subject to conditions imposed by the law.
Under GST, a supplier must upload all Business-to-Business (B2B) supplies in GSTR-1 on the GST portal. This allows the buyer to verify whether the transaction has been correctly reported by the supplier. If the supplier does not upload the transaction, the buyer cannot claim Input Tax Credit on that supply. Further, as per Section 16(2)(c), the buyer is entitled to ITC only when the supplier has actually paid the tax on the supply, either in cash or by using available ITC.
It is also possible that the supplier has uploaded the supply details in GSTR-1 on the GST portal but has failed to deposit the tax collected from the purchaser while filing GSTR-3B under Section 39 of the Act. In such cases, the department has denied Input Tax Credit to the purchaser, even though the purchaser has already paid the GST amount to the supplier.
Judgment in Sahil Enterprises (Tripura High Court)
It is pertinent to note that a writ petition was filed challenging the constitutional validity of Section 16(2)(c) of the CGST Act on the ground that it violates Articles 14, 19(1)(g), and 300-A of the Constitution of India. The challenge was raised in Sahil Enterprises v. Union of India & Ors., WP (C) No. 688 of 2022, decided on 06.01.2026 by the High Court of Tripura at Agartala. The Division Bench comprising Justice S. Datta Purkaystha and Justice M.S. Ramachandra Rao held that Section 16(2)(c) of the Act is not violative of Articles 14, 19(1)(g), 265, or 300-A of the Constitution of India. But Section 16(2) (c) of the Act ought not to be interpreted to deny ITC to purchasers in a bona fide transaction like the petitioner and it should be read down and applied only where the transaction is found to be not bona fide or is a collusive transaction or fraudulent transaction to defraud the revenue.
The Hon’ble Court in (para 19 & 20 ) held that in our opinion, there is a failure by the Parliament, while enacting Section 16 (2)(c) of the Act, to make a distinction between purchasing dealers who have bona fide transacted with the selling dealer by taking all precautions as required by the Act and those that have not. Therefore, there is need to restrict the denial of ITC only to the selling dealers who had failed to deposit the tax collected by them and not punish bona fide purchasing dealers. The purchasing dealer cannot be asked to do the impossible, i.e., to identify a selling dealer who will not deposit with the Government, the tax collected by him from purchasing dealers, and avoid transacting with such selling dealers.
Section 16(2)(c) of the Act effectively requires the purchasing dealer to ensure that the selling dealer actually deposits the tax collected from him. If the selling dealer fails to do so, the purchasing dealer faces the risk of denial of ITC. Such a requirement places an unreasonable burden on the purchasing dealer, as it is practically impossible for him to ensure that the selling dealer has deposited the GST with the Government. So section 16(2) (c) of the Act places an onerous burden on a bona fide purchasing dealer. In these circumstances, if the law imposes disproportionate consequences on a bona fide purchasing dealer, it would be vulnerable to challenge as violative of Article 14 of the Constitution. (para 21 to 23)
Judgment in MCLEOD Russel India Limited (Gauhati High Court)
It is to be noted that in MCLEOD Russel India Limited vs. Union of India and ors. WP(C) NO.5725 OF 2022 dated 9th December, 2025 (Neutral Citation: 2025:GAU-AS:16974-DB] the Hon’ble Gauhati High Court held that “we are not inclined to hold the amendment in Section 16 to be unconstitutional but for the present, we only read it down to the extent that in case of the supplier acting truant, before denying the ITC benefits to a bona fide purchaser, he ought to be given an opportunity to prove his bona fides, which can be verified by the tax invoices and other documents.”
It means court held that we do not consider the amendment to Section 16 to be unconstitutional. However, if the supplier defaults, ITC should not be denied to an honest buyer without giving the buyer a chance to prove that the transaction was genuine, based on invoices and other supporting documents.
The Hon’ble Gauhati High Court further held that “we have read down this provision only till the time CBIC comes out with any practical solution to the problem posed by making the availability of ITC to the bona fide purchaser contingent on factors which are totally in the hands of a supplier and not the purchaser.”
Contentions of the Petitioner (General)
1. The scheme of Input Tax Credit is designed to avoid the burden of double taxation on the taxpayer.
2. One of the fundamental objectives of the CGST Act is to levy tax only on value addition and to eliminate the cascading effect of taxes.
3. Denial of ITC to the purchaser and compelling him to pay tax again to the Government, despite having already paid GST to the supplier, results in double collection of tax and violates Article 265 of the Constitution of India.
4. The respondents do not dispute that there is no mechanism available to the recipient of goods or services to verify whether the supplier has discharged its tax liability to the Government. In the absence of such a mechanism, it is impossible for the purchaser to ascertain whether the tax paid to the supplier has been deposited with the Government before availing ITC.
5. The supplier is not under the control of the purchaser. It is undisputed that a purchaser cannot monitor the activities of the supplier or ensure that the GST collected by the supplier is deposited with the Government.
6. Denial of ITC to a bona fide purchaser, who has paid GST to the supplier, is arbitrary and unreasonable and violates Articles 14, 19(1)(g), and 300A of the Constitution of India.
7. The purchaser cannot be faulted for the failure of the supplier to deposit the tax collected from him. Penalising the purchaser for the default of the supplier amounts to punishing one person for the fault of another.
8. The purchasing dealer cannot be required to do the impossible, namely, to identify in advance a selling dealer who may fail to deposit tax with the Government and to avoid transacting with such dealer.
9. Section 16(2)(c) of the Act effectively casts an obligation on the purchasing dealer to ensure that the selling dealer deposits the tax collected from him. If the selling dealer defaults, the purchasing dealer faces denial of ITC. Such a requirement imposes an unreasonable and impracticable burden on the purchasing dealer.
10. Consequently, Section 16(2)(c) of the Act places an onerous and disproportionate burden on a bona fide purchasing dealer.
11. Viewed from another perspective, denial of ITC to the buyer for the default of the supplier amounts to shifting the incidence of tax from the supplier to the buyer, which is unconstitutional and contrary to the scheme of the CGST Act.
12. As a result, the buyer is made to pay GST twice on the same transaction—once at the time of purchase by paying GST to the supplier and again upon disallowance of ITC.
13. The Central Board of Indirect Taxes and Customs (CBIC), vide Circular No. 183/15/2022-GST dated 27.12.2022 and Circular No. 193/05/2023-GST, had provided a mechanism up to 31.12.2021 to allow ITC to recipients where details were not uploaded or correctly reported in Form GSTR-1 by the supplier, resulting in non-reflection in Form GSTR-2A. There is no rational basis to assume that such errors or defaults would not occur even after 01.01.2022.
Doctrine of Reading Down
In Sahil Enterprises (supra), the petitioner argued that reading down is an accepted method used by courts to save a provision from being unconstitutional. It was submitted that this principle should also be applied in the present case so that Section 16(2)(c) is interpreted in a manner that does not unfairly penalize a genuine recipient for the default of the supplier.
In B.R. Enterprises v. State of U.P. (1999) 9 SCC 700 : (2000) 120 STC 302, at page 764 , the situation where such a principle of reading down can be applied is explained in the following terms:
“81. ….. Similarly, for upholding any provision, if it could be saved by reading it down, it should be done, unless plain words are so clear to be in defiance of the Constitution. These interpretations spring out because of concern of the courts to salvage a legislation to achieve its objective and not to let it fall merely because of a possible ingenious interpretation. The words are not static but dynamic. This infuses fertility in the field of interpretation. This equally helps to save an Act but also the cause of attack on the Act. Here the courts have to play a cautious role of weeding out the wild from the crop, of course, without infringing the Constitution. For doing this, the courts have taken help from the Preamble, Objects, the scheme of the Act, its historical background, the purpose for enacting such a provision, the mischief, if any which existed, which is sought to be eliminated.”
In CST v. Radhakrishan (1979) 2 SCC 249 : (1979) 118 ITR 534, at page 257 , sanction for prosecution of a dealer under the M.P. General Sales tax Act was given by the Commissioner of Taxes under section 46 (1) (c) of the said Act, though there was a procedure for recovery of tax by imposing penalty under section 22(4-A) of the said Act. The validity of the sanction was questioned on the ground that under the Sales Tax Act, the Commissioner is entitled to pursue two different procedures for enforcing and realizing the assessment made, but as there is no guidance as to the circumstances in which he should resort to either of the two procedures, the provision regarding grant of sanction is invalid. Rejecting the said contention and reading down the provision enabling prosecution for failure to pay tax by a dealer, the Supreme Court held:
“15 . … …. In considering the validity of a statute the presumption is in favour of its constitutionality and the burden is upon him who attacks it to show that there has been a clear transgression of constitutional principles. For sustaining the presumption of constitutionality the court may take into consideration matters of common knowledge, matters of common report, the history of the times and may assume every state of facts which can be conceived. It must always be presumed that the Legislature understands and correctly appreciates the need of its own people and that discrimination, if any, is based on adequate grounds. It is well settled that courts will be justified in giving a liberal interpretation to the section in order to avoid constitutional invalidity. These principles have given rise to rule of reading down the sections if it becomes necessary to uphold the validity of the sections. In the present case it is seen, under Section 46 before a prosecution can be launched, it is necessary that the assessee should have failed to pay the tax due within the time allowed without reasonable cause. The duty of the Commissioner is, therefore, to be satisfied that the assessee has failed without reasonable cause and without recourse to prosecution under Section 46(1)(c), the tax due cannot be collected. The provisions of Section 22(4-A) can be read as being applicable to cases in which the stringent step of prosecution is considered not necessary. The option is with the Commissioner and if he thinks levy of penalty would achieve the purpose of collection of the tax he can have recourse to the provisions of Section 22(4-A). Before levying a penalty under Section 22(4-A), the Commissioner shall give reasonable opportunity of being heard as to why the penalty should not be levied. Reading the two provisions harmoniously, we are of the view that the discretion is given to the Commissioner to resort to one of the two remedies as the facts of the case may require. In graver cases he will be justified in taking the drastic remedy and resorting to prosecution in the criminal court if he is satisfied that such a course is necessary for the collection of the tax expeditiously. If the discretion is not properly exercised the court may be justified in interfering in such cases but the law cannot be held to be invalid.”
(emphasized supplied)
A provision similar to Section 16(2)(c) of the Act also existed in Section 9(2) (g) the Delhi Value Added Tax Act, 2004. This provision was considered by the Delhi High Court in Quest Merchandising India Pvt. Ltd and others v. Government of NCT of Delhi and others (2017) SCC ONLINE DELHI 13037. Section 9(1) of DVAT Act permits ITC to a registered dealer in respect of turnover of purchases occurring during the tax period where the purchase arises in the course of his activities as a dealer and the goods are to be used by him directly or indirectly for the purpose of making sales which are liable to tax under Section 7 of the DVAT Act. Sub section (2) of Section 9 sets out the conditions under which such ITC would not be allowed. Clause (g) of sub-section (2) of Section 9 made ITC benefit available to a purchasing dealer only when the tax paid by the purchasing dealer has actually been deposited by the selling dealer with the Government or has been lawfully adjusted against output tax liability and correctly reflected in the return filed for the respective tax period. Reading down clause (g) of sub-section (2) of Section 9, in Quest Merchandising India (supra), the Delhi High Court held:
“39. Applying the law explained in the above decisions, it can be safely concluded in the present case that there is a singular failure by the Legislature to make a distinction between purchasing dealers who have bona fide transacted with the selling dealer by taking all precautions as required by the DVAT Act and those that have not. Therefore, there was need to restrict the denial of ITC only to the selling dealers who had failed to deposit the tax collected by them and not punish bona fide purchasing dealers. The latter cannot be expected to do the impossible. It is trite that a law that is not capable of honest compliance will fail in achieving its objective. If it seeks to visit disobedience with disproportionate consequences to a bona fide purchasing dealer, it will become vulnerable to invalidation on the touchstone of article 14 of the Constitution.
40. … …
41. The court respectfully concurs with the above analysis and holds that in the present case, the purchasing dealer is being asked to do the impossible, i.e., to anticipate the selling dealer who will not deposit with the Government the tax collected by him from those purchasing dealer and therefore avoid transacting with such selling dealers. Alternatively, what section 9(2)(g) of the DVAT Act requires the purchasing dealer to do is that after transacting with the selling dealer, somehow ensure that the selling dealer does in fact deposit the tax collected from the purchasing dealer and if the selling dealer fails to do so, undergo the risk of being denied the ITC. Indeed section 9(2)(g) of the DVAT Act places an onerous burden on a bona fide purchasing dealer. ……. …
53.. In light of the above legal position, the Court hereby holds that the expression ‘dealer or class of dealers’ occurring in Section 9 (2) (g) of the DVAT Act should be interpreted as not including a purchasing dealer who has bona fide entered into purchase transactions with validly registered selling dealers who have issued tax invoices in accordance with Section 50 of the Act where there is no mismatch of the transactions in Annexures 2A and 2B. Unless the expression ‘dealer or class of dealers’ in Section 9 (2) (g) is ‘read down’ in the above manner, the entire provision would have to be held to be violative of Article 14 of the Constitution.
54. The result of such reading down would be that the Department is precluded from invoking Section 9 (2) (g) of the DVAT to deny ITC to a purchasing dealer who has bona fide entered into a purchase transaction with a registered selling dealer who has issued a tax invoice reflecting the TIN number. In the event that the selling dealer has failed to deposit the tax collected by him from the purchasing dealer, the remedy for the Department would be to proceed against the defaulting selling dealer to recover such tax and not deny the purchasing dealer the ITC. Where, however, the Department is able to come across material to show that the purchasing dealer and the selling dealer acted in collusion then the Department can proceed under Section 40A of the DVAT Act.” (emphasis supplied)
The aforesaid decision of the High Court was challenged before the Supreme Court in Commissioner of Trade and Tax Delhi v. M/s Arise India Ltd. Special Leave to Appeal (Civil) No.36750 of 2017 dt. 10.1.2018. The said Special Leave petition was dismissed without interfering with the order of the High Court. The Supreme Court held:
“On hearing learned Additional Solicitor General appearing for the petitioner, we are not inclined to interfere with the impugned order. The Special Leave Petition is dismissed.
Learned Additional Solicitor General, however, submits that a batch of petitions were decided by the impugned order and there are some of the cases where the purchase transactions arenot bona fide like the present case and those cases ought to have been remitted back to the competent authority.
Learned Additional Solicitor General submits that the petitioner would move the High Court with necessary particulars for directions in this behalf for which liberty is granted, as prayed for.”
The same issue again arose in the Delhi High Court in M/s Shanti Kiran India (P) Ltd v. The Commissioner Trade and Tax, Delhi. STA No.34 of 2012 and batch dt.4.1.2013 (Delhi High court) i.e whether the benefit of ITC is available to the registered purchaser dealers who paid taxes to the registered seller dealer(s) in terms of invoice(s) raised by them even though those seller dealers did not deposit the collected tax with the Government. The Delhi High Court held in favour of the purchaser dealers and against State.
This judgment was again challenged in the Supreme Court in The Commissioner Trade and Tax, Delhi v. M/s Shanti Kiran India (P) Ltd. Civil Appeal No.9902 of 2017 dt.9.10.2025. The Supreme Court followed the decision of the Delhi High Court in Quest Merchandising India Pvt.Ltd (Supra) as affirmed by the Supreme Court in M/s Arise India (Supra) and held:
“In light thereof, as we find that there is no dispute regarding the selling dealer being registered on the date of transaction and neither the transactions nor invoices in questions have been doubted, based on any inquiry into their veracity, we do not find a good reason to interfere with the order of the High Court directing for grant of ITC benefit after due verification. The appeals lack merit and are, accordingly, dismissed.”
In this matter, the High Court of Tripura has held that we are of the view that the same reasoning as adopted by the Delhi High Court in On Quest Merchandising India Pvt.Ltd (supra) and M/s Shanti Kiran India (P) Ltd (supra) as approved by the Supreme Court, should be adopted to the interpretation of Section 16(2) (c) of the Act. It should not be interpreted to deny ITC to genuine purchasers. The provision must be applied only where the transaction is not genuine or is collusive or fraudulent and intended to defraud the revenue.
The Gauhati High Court, in National Plasto Moulding v. State of Assam (2024) 8 TMI 836= 2024(89) GSTL 82 (Gau), examined the constitutional validity of Section 16(2)(c) of the Act and held that the issue was already covered by the judgment of the Delhi High Court in On Quest Merchandising India Private Limited (supra), as affirmed by the Supreme Court in Arise India (supra). The Court read down Section 16(2)(c) and held that it cannot be applied to a purchasing dealer who had entered into bona fide purchase transactions with duly registered selling dealers. Accordingly, the show cause notices and the consequential orders challenged in the writ petitions were set aside. However, the Court clarified that the Department is at liberty to proceed in cases where the purchase transactions are found to be not bona fide. The same view was reiterated by the Gauhati High Court in M/s McLeod Russel India Ltd. v. Union of India and Others. It is stated at the Bar that the Special Leave Petition filed against the judgment in National Plasto Moulding was dismissed by the Supreme Court by a non-speaking order, and that no Special Leave Petition was filed by the Union of India against the judgment in M/s McLeod Russel India Ltd.
The High Court of Tripura has considered that the High Courts have upheld the constitutionality of Section 16(2) (c) of the Act without reading it down. They are:
b. Patna High Court in Aastha Enterprises v. State of Bihar 2023 SCC Online Pat 4395
c. Madhya Pradesh High Court in M/s Shree Krishna Chemicals v.Union of India 2025 (2) TMI 1006 (M.P)
The High Court of Tripura (in para 40) held that these High Courts are of the view that the legislature has wide discretion to frame and adjust taxation laws in a reasonable manner. A tax statute can be declared unconstitutional only if it clearly violates the fundamental rights under Part III of the Constitution. Input Tax Credit is treated as a statutory benefit or concession, and even if regarded as an entitlement, it is subject to the conditions and restrictions prescribed under the GST law, particularly Sections 16(2) to 16(4), Section 43, and the relevant Rules. ITC is therefore not an absolute right. Under the scheme of the Act, only tax that is actually paid to the Government can be allowed as ITC; if the tax has not reached the Government, ITC cannot be granted. Some courts have further held that taxation statutes should not be lightly interfered with and that courts must exercise judicial restraint unless the law is clearly arbitrary or unconstitutional. Challenges under Article 14 were found to be vague, and it was observed that the purchaser’s remedy lies in recovering the tax amount from the defaulting seller.
However, none of the above High Courts have examined the practical difficulty faced by a purchaser in ensuring that the seller actually pays the GST to the Government, especially when the purchaser has no effective mechanism or means to verify whether such tax has been paid. While there is no dispute with the general principles laid down in those judgments, their failure to consider this important practical aspect does not persuade us to follow their view.
Another crucial aspect is that none of the decisions of the other High Courts referred to above have considered or even noticed the binding judgments of the Delhi High Court in On Quest Merchandising India Pvt. Ltd. and others v. Government of NCT of Delhi and others (2017 SCC OnLine Del 13037) and M/s Shanti Kiran India (P) Ltd. v. The Commissioner, Trade and Tax, Delhi (STA No. 34 of 2012 and connected matters, decided on 04.01.2013). Both these judgments were subsequently approved by the Supreme Court in Commissioner of Trade and Tax, Delhi v. M/s Arise India Ltd. (SLP (Civil) No. 36750 of 2017, decided on 10.01.2018)and The Commissioner, Trade and Tax, Delhi v. M/s Shanti Kiran India (P) Ltd. (Civil Appeal No. 9902 of 2017, decided on 09.10.2025), respectively.
The absence of any discussion on these precedents significantly weakens the persuasive value of those decisions. Had these binding and relevant judgments been placed before those High Courts, they might have adopted the same approach as that taken by the Delhi High Court and affirmed by the Supreme Court.
The view taken by the Delhi High Court in its judgments under the DVAT Act, which contained a similar provision in Section 9(2)(g), and which have been accepted by the Supreme Court, appeals to us and, in our opinion, provides a more appropriate approach to the issue. Accordingly, Section 16(2)(c) deserves to be read down in the same manner as was done by the Delhi High Court. Had the other High Courts referred to above examined the issue in this manner while upholding the constitutionality of the provision, they too may have read it down in a similar way.
Double Taxation Aspect
The High Court of Tripura (in para 44) recognised that it is a settled principle of taxation law that, unless expressly provided otherwise, the same income or transaction cannot be taxed twice (Laxmipat Singhania v. CIT AIR 1969 SC 501). There is no dispute that the concept of Input Tax Credit has been introduced to prevent the burden of double taxation on a taxpayer.
In Mahaveer Kumar Jain v. CIT15, the Supreme Court held:
“21. Further, in a decision of this Court in Jain Bros. v. Union of India (1969) 3 SCC 311, it has been held as under: (SCC pp. 315-16, para 6)
“6. It is not disputed that there can be double taxation if the legislature has distinctly enacted it. It is only when there are general words of taxation and they have to be interpreted, they cannot be so interpreted as to tax the subject twice over to the same tax.… If any double taxation is involved, the legislature itself has, in express words, sanctioned it. It is not open to any one thereafter to invoke the general principles that the subject cannot be taxed twice over.”
22. The above referred cases make it clear that there is no prohibition as such on double taxation provided that the legislature contains a special provision in this regard. Now, the only question that remains to be decided is whether in fact there is a specific provision for including the income earned from the Sikkim lottery ticket prior to 1-4-1990 and after 1975, in the income tax return or not. We have gone through the relevant provisions but there seems to be no such provision in the IT Act wherein a specific provision has been made by the legislature for including such an income by an assessee from lottery ticket. In the absence of any such provision, the assessee in the present case cannot be subjected to double taxation.”
(emphasis supplied)
The High Court of Tripura (in para 45 & 46) recognised that we do not find anything in the language of the Act that expressly authorises the respondents to tax a purchaser, who has already paid tax to the seller, a second time by denying Input Tax Credit in all situations. If such an interpretation were accepted, the very concept of granting ITC under the Act would become meaningless. We are of the view that the other High Courts have overlooked the important principle that Input Tax Credit was introduced under the GST regime to avoid the burden of double taxation on a taxpayer. In our opinion, although Parliament intended ITC to operate as a statutory benefit or concession, it did not intend to penalise a bona fide taxpayer by denying ITC where the transaction with the seller or supplier is genuine.
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GST genuine Vyapari ke liye Kaal hai orr Tax Choron ke liye Vardan kyun orr kisne aisa wrong system banaya iski proper janch hona chahiye..Kitne case kitne Demand notices Vyapari karobaar kaise orr kisasse karre jabki Registration tohh Department hi karta hai firr Purchaser ko Preshani kyun .Ya tohh tax amount direct portal pe hi deposit karne ka system hona chahiye tha.