Brief Facts:

The petitioner approached the High Court with a writ petition under Article 226 of the Indian Constitution, seeking a refund of Input Tax Credit (ITC) totaling ₹40,10,932 for the fiscal year April 2018 to March 2019. A deficiency memo dated 31.12.2019 was issued citing the absence of supporting documents and was advised to reapply with the necessary corrections. 
The petitioner faced a roadblock as the online portal had been closed, and their manual submission was rejected by the authorities. The petitioner argued that the portal’s closure hindered their ability to adhere to the deficiency memo’s directives, thereby preventing the online correction of the application. The petitioner prayed before the court to instruct the authorities to either process the existing application or permit the manual submission of the requisite documents.

Issue:

Whether the petitioner should be granted the opportunity to manually file the refund application and address the deficiencies, given the inaccessibility of the online portal?

Court’s Ruling:

The Andhra Pradesh High Court affirmed that procedural norms should serve to advance justice, not thwart valid claims. The court decreed that the petitioner’s right to a refund should not be negated due to the online portal’s unavailability. Consequently, the court sanctioned the manual filing of the refund application, mandating the submission of the essential documents to remedy the deficiencies within a fortnight. The designated authority was instructed to evaluate the refund claim and render a decision within a six-week timeframe, ensuring that the manual filing would not constitute grounds for rejection.

My GST Refund Opinion:

The court’s verdict exemplifies a judicious balance between procedural rigor and equitable resolution. It accentuates the notion that procedural regulations are designed to facilitate, not frustrate, the grievance redressal process. The decision safeguards taxpayer rights amidst technological snags and highlights the necessity for administrative adaptability and receptiveness. This ruling carves out a pivotal precedent for accommodating legitimate instances where procedural hurdles obstruct the course of justice.