Human Error Led to ₹1 Crore GST ITC Availment instead of ₹1 Lakh: Orissa HC Remits Matter for Rectification

The Orissa High Court addressed an error in a Goods & Services Tax return whereby an assessee, Gautam Pattnaik, claimed Input Tax Credit (ITC) of over ₹1 crore instead of what should have been approximately ₹1 lakh, because of a decimal shift error during GSTR filings. The inflated figure triggered a demand of about ₹3.27 crore (combining CGST and SGST) under Section 73 of the GST Act. Pattnaik lodged an application under Section 161 seeking rectification, but it was rejected on limitation grounds. He also reversed the excess ITC in GSTR-3B upon noticing the mistake. The High Court held that human / clerical / arithmetic errors should be permitted to be corrected, especially when no mala fide intent is evident. It set aside the Assistant Commissioner’s order denying rectification and remitted the matter to the assessing authority with directions to allow correction within four weeks and adjust the order under Section 73 accordingly