2025 (1) TMI 922 - HC - GST

Maintainability of writ petition filed by the appellant - discrepancies in the data migration from the Legacy ACES Application to the new Integrated ACES-GST Application affected the appellant's tax liabilities - According to the appellant, when the data was populated, there is error wherein PART B of the revised return was not duly populated into the domain of the Department. - HELD THAT - The case of the appellant/assessee has to be accepted and necessary rectification has to be done. Pursuant to the stand taken by the department, the Portal has to be created and thereafter a revised order has to be passed. The impugned order set aside with a direction to the authorities to make the necessary correction in the Portal and issue a revised order accepting the stand taken by the appellant/assessee - appeal allowed.

Summary

1. ISSUES PRESENTED and CONSIDERED

The judgment revolves around the following core legal issues:

• Whether the writ petition filed by the appellant was maintainable.
• Whether discrepancies in the data migration from the Legacy ACES Application to the new Integrated ACES-GST Application affected the appellant's tax liabilities.
• Whether the department should rectify the data discrepancies and issue a revised order.
• Whether the proceedings against the appellant should be quashed based on the data discrepancies.

2. ISSUE-WISE DETAILED ANALYSIS

Issue 1: Maintainability of the Writ Petition

• Relevant Legal Framework and Precedents: The court considered the principles governing the maintainability of writ petitions, particularly in cases where statutory remedies may not provide adequate relief.
• Court's Interpretation and Reasoning: The court found the writ petition maintainable, noting that the issue could not be resolved by the adjudicating authority or the tribunal, and required judicial intervention.
• Key Evidence and Findings: The court referred to the discrepancies identified between the original and revised returns filed by the appellant.
• Application of Law to Facts: The court determined that the writ court could issue directions for rectification if the appellant's submission was found correct.
• Treatment of Competing Arguments: The court acknowledged the appellant's argument regarding data errors and found merit in judicial intervention.
• Conclusions: The writ petition was deemed maintainable.

Issue 2: Data Discrepancies in Migration

• Relevant Legal Framework and Precedents: The case involved the procedural aspects of data migration in tax systems and the legal obligations of the authorities to ensure accurate data handling.
• Court's Interpretation and Reasoning: The court noted that the revised data had not been fully migrated to the new system, leading to discrepancies in the appellant's tax records.
• Key Evidence and Findings: The court reviewed affidavits and tables showing discrepancies between the original and revised returns.
• Application of Law to Facts: The court accepted the appellant's claim that the data discrepancies were not their fault and required rectification by the department.
• Treatment of Competing Arguments: The department's acknowledgment of the data migration issue supported the appellant's case.
• Conclusions: The court concluded that the appellant's case was valid and required departmental action for rectification.

Issue 3: Rectification and Issuance of Revised Order

• Relevant Legal Framework and Precedents: The court considered the procedural requirements for rectifying administrative errors in tax records.
• Court's Interpretation and Reasoning: The court directed the department to rectify the discrepancies and issue a revised order.
• Key Evidence and Findings: The department's affidavit confirmed the need for rectification.
• Application of Law to Facts: The court ordered the department to make necessary corrections in the tax portal and issue a revised order.
• Treatment of Competing Arguments: The court dismissed the department's potential arguments against rectification due to their acknowledgment of the issue.
• Conclusions: The court ordered rectification and the issuance of a revised order.

Issue 4: Quashing of Proceedings

• Relevant Legal Framework and Precedents: The court considered the implications of administrative errors on ongoing legal proceedings.
• Court's Interpretation and Reasoning: While the appellant sought to quash the proceedings, the court focused on rectification rather than quashing.
• Key Evidence and Findings: The court relied on the department's acknowledgment of errors.
• Application of Law to Facts: The court found that rectification was the appropriate remedy rather than quashing the proceedings.
• Treatment of Competing Arguments: The court balanced the appellant's request with the need for procedural compliance by the department.
• Conclusions: The court did not quash the proceedings but directed rectification.

3. SIGNIFICANT HOLDINGS

• Verbatim Quotes of Crucial Legal Reasoning: "In the light of the above stand taken by the department, the case of the appellant/assessee has to be accepted and necessary rectification has to be done."
• Core Principles Established: The court emphasized the duty of tax authorities to ensure accurate data migration and rectify errors affecting taxpayers.
• Final Determinations on Each Issue:
  • The writ petition was maintainable.
  • The department was responsible for rectifying data discrepancies.
  • A revised order was to be issued by the department.
  • The proceedings were not quashed, but rectification was mandated.