Anjani Seeds And Fertilizers Depo Vs State of Gujarat (Gujarat High Court)
The Gujarat High Court heard a writ petition challenging an adjudication order dated 1 January 2025 and the subsequent appellate order dated 18 June 2025 passed under the Gujarat Goods and Services Tax Act, 2017. The petitioner, a proprietorship registered under the GST Act engaged in trading chemical fertilizers and cement, sought to quash both orders.
The controversy arose after the petitioner received an intimation in Form GST DRC-01A on 11 June 2024, proposing a demand under Section 73 of the Act for the 2020-21 assessment year. A show-cause notice in Form GST DRC-01 followed on 3 September 2024, alleging two grounds: (i) differences between input tax credit claimed in Form GSTR-3B and Form GSTR-2A, and (ii) claiming blocked credit under Section 17(5). The petitioner responded with a detailed reply on 19 October 2024, explaining that the differences arose solely because credit notes from the petitioner’s supplier were reported as output tax liability instead of reducing input tax credit. Despite these explanations, the adjudicating authority passed the order on 1 January 2025 confirming the demand based on the GSTR-3B and GSTR-2A difference, while dropping the issue under Section 17(5).
