GSTR-3B vs 2A Mismatch: ITC Reversal Order Set Aside for Ignoring Mandatory Circular

R.S. Marketing And Logistics Private Limited Vs Commercial Tax Officer (Karnataka High Court) The petitioner challenged an adjudication order dated 02.05.2023, issued on the ground that discrepancies existed between ITC claimed in GSTR-3B and GSTR-2A. The petitioner contended that adequate opportunity to explain the mismatch was not provided and that the authority failed to follow the procedure prescribed in Circular No. 183/15/2022-GST dated 27.12.2022, which applies to FY 2017-18 and prescribes specific steps where ITC differences are below ₹5,00,000. The Revenue argued that sufficient opp...