M/s Vishist Business Solutions Private Limited v. Appellate Joint Commissioner of State Tax (ST) & Ors.

Introduction

The dispute arose from an assessment for the financial year 2018-19, wherein the Proper Officer passed an Order-in-Original dated 18.04.2024 under Section 73 of the Telangana Goods and Services Tax Act, 2017, disallowing Input Tax Credit (ITC) claimed by the petitioner. The demand was primarily based on the allegation that there was a mismatch between the ITC availed in GSTR-3B and the details available in GSTR-2A, thereby violating the condition prescribed under Section 16(2)(c) of the Act.

The petitioner preferred an appeal, but the Appellate Authority, by order dated 19.11.2025, affirmed the assessment. The appellate authority observed that the petitioner had failed to produce the supplier’s Chartered Accountant’s certificate as contemplated under CBIC Circular No. 183/15/2022-GST dated 27.12.2022, which provides relief in cases involving mismatch between GSTR-2A and GSTR-3B for FY 2017-18 and FY 2018-19.