Introduction

This judgment of the Kerala High Court examines the time limit prescribed under Section 39(9) of the CGST Act for rectification of errors in GST returns. The Court held that an application for rectification filed far beyond the statutory limitation period cannot be entertained, even if the taxpayer claims that the error was inadvertent.

The Court further observed that where the taxpayer himself seeks rectification of an assessment order on account of his own mistake, such conduct amounts to an admission of error, making a simultaneous challenge to the assessment order on merits untenable. Accordingly, the Court upheld the dismissal of the writ petition and refused to direct the authorities to consider a time-barred rectification application.