GST Portal To Be Opened For GSTR-1 Rectification | HC

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GSTR-1 Rectification Portal Opening HC

Case Details: Ambica Auto Sales and Service vs. Union Bank of India - [2026] 182 taxmann.com 434 (Gujarat)

Judiciary and Counsel Details

  • A.S. Supehia & Pranav Trivedi, JJ.
  • Uchit N Sheth for the Petitioner.
  • CB Gupta for the Respondent.

Facts of the Case

The petitioner contested the denial of rectification of Form GSTR-1 and Form GSTR-3B despite an ITC mismatch arising from portal-related errors. It availed ITC on vendor invoices, and vendors issued credit notes for post-sale discounts. The portal matched only credit notes and ignored debit notes, and the petitioner reported the discount in the wrong field, causing a mismatch in Form GSTR-2A. It was submitted that there was no loss of revenue, and the petitioner requested that the portal be opened for rectification or manual correction be allowed. The matter was accordingly placed before the High Court.

High Court Held

The High Court held that there was no revenue loss, as the tax paid on debit notes exceeded the proposed ITC reversal, and the error was confined to reporting rather than liability. It was noted that the Department showed no variance in actual tax due. The Court directed the jurisdictional officer under CGST to open the portal to enable rectification of Form GSTR-1 and Form GSTR-3B under Section 39 of the CGST Act and the Gujarat GST Act, and in case the portal was not opened, manual rectification was to be accepted. Consequently, the impugned order was quashed.

List of Cases Referred to

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Author: Taxmann

Taxmann Publications has a dedicated in-house Research & Editorial Team. This team consists of a team of Chartered Accountants, Company Secretaries, and Lawyers. This team works under the guidance and supervision of editor-in-chief Mr Rakesh Bhargava.

The Research and Editorial Team is responsible for developing reliable and accurate content for the readers. The team follows the six-sigma approach to achieve the benchmark of zero error in its publications and research platforms. The team ensures that the following publication guidelines are thoroughly followed while developing the content:

  • The statutory material is obtained only from the authorized and reliable sources
  • All the latest developments in the judicial and legislative fields are covered
  • Prepare the analytical write-ups on current, controversial, and important issues to help the readers to understand the concept and its implications
  • Every content published by Taxmann is complete, accurate and lucid
  • All evidence-based statements are supported with proper reference to Section, Circular No., Notification No. or citations
  • The golden rules of grammar, style and consistency are thoroughly followed
  • Font and size that's easy to read and remain consistent across all imprint and digital publications are applied