Denial of Tax Credit Violates Articles 14 & 300A: CESTAT Holds Rejection of Transitional Credit Refund on Limitation Grounds Unsustainable

The Customs, Excise, and Service Tax Appellate Tribunal (CESTAT) has issued a significant ruling stating that the denial of a transitional credit refund purely on the grounds of arbitrary limitation periods violates the constitutional principles enshrined in Articles 14 (Equality before law) and 300A (Right to property). The tribunal emphasized that the right to claim legitimate transitional credit, which facilitates the shift from the old tax regime to GST, cannot be extinguished by an arbitrary time limit. This decision provides crucial relief to taxpayers who might have been denied credit due to procedural delays or restrictive interpretations of limitation periods.