Question 48:An assessee has claimed
credit on the basis of invoice/ Bill of entry issued in January 17 in revised
TRANS 1 stating it was left to take credit in his ER 1/ST 3. Now they have
claimed credit of the same. During the verification of Trans 1 , whether it can
be allowed or denied' And under which specific authority, section, rules,
notification, circular' Kindly reply urgently. With regards
Answer The credit of ITC (CENVAT and balance of VAT) is available under
section 140 .This section permits credit of the balance shown in the last return
as per the information provided by you this credit is not taken in the returns
filed under the earlier regime
You should first file amended return for the earlier period if this is possible
then your are free from litigation but if this is not possible then you take
decision as follow
If the amount is small then claim it and be ready to reverse it if no amendment
is issued or no clarification is issued by the GST council and department raises
objection
But if the amount is good and it is justified to go for litigation then claim
the credit and go for litigation because as law point it should be given to you
because as per Earlier laws you were entitled to take credit with in the time
limit and you could claim it if there was no change in law
There are number of settled cases where it is decided that a fundamental benefit
can not be denied for technical and procedural requirement.(REPLY dt. 23/1/2018)