Debit notes were reported in the wrong column in GSTR-1 causing ITC mismatch; authorities directed to reopen the portal to allow rectification of GSTR-1 and GSTR-3B, or permit manual correction. { Ambica Auto Sales and Service vs. Union Bank of India [2026] 182 taxmann.com 434 (Gujarat)}
Facts
- The assessee issued debit notes to its vendor for discounts given by the vendor.
- These debit notes were reported in the wrong column in the Form GSTR-1 filed by the assessee.
- As a result, the Input Tax Credit (ITC) shown in the assessee’s GSTR-1 did not match the ITC reflected in the vendor’s Form GSTR-2A of the recipient.
- Due to this mismatch, the department raised a GST demand / disallowed ITC in the assessment proceedings.
Issue
- Whether the assessee should be permitted to rectify the mistake in filing Forms GSTR-1 and GSTR-3B (due to wrong reporting of debit notes), and if so, how — by opening the GST portal for corrections or allowing manual rectification if portal is not enabled.
Held
- The mistake in filing the debit note in the wrong column caused a mismatch in the ITC reflected in GSTR-2A.
- The department was directed to open the GST common portal to allow the assessee to rectify/ amend the Forms GSTR-1 and GSTR-3B.
- If the portal cannot be opened or made available for the period in question, the assessee must be allowed to file an application to manually amend/ rectify the incorrect GSTR-1 and GSTR-3B.
- This ensures the matching of ITC and removal of the unwarranted demand.
