GST Demand raised on Non-Reflection of Credit Note Values and its ITC Reversal in GSTR 2A: Madras HC grants Liberty to File Late GST Appeal with 15% Pre-Deposit

The Madras High Court has granted a taxpayer the liberty to file a late GST appeal upon payment of a 15% pre-deposit. The case involved a GST demand raised due to the non-reflection of credit note values and their corresponding Input Tax Credit (ITC) reversal in the GSTR-2A form of the recipient. The taxpayer had missed the statutory deadline for filing an appeal against the demand order. Acknowledging the taxpayer's intent to contest the demand on its merits, the High Court used its discretion to allow the late filing of the appeal. The condition of a 15% pre-deposit was imposed to safeguard the revenue's interests while providing the taxpayer an opportunity to have their case heard by the appellate authority. This order demonstrates a balanced judicial approach, ensuring that substantive justice is not denied on purely procedural grounds of delay, provided the taxpayer shows commitment by partially securing the disputed amount.