11052026 Absence Of Pmt 03 Functionality On The GST Portal Cannot Be Used As A Ground To Deny Legitimate Re Credit Of IT
On May 10, 2026, courts affirmed that the absence of PMT-03 functionality cannot justify denying legitimate ITC claims.
The inability to utilize the PMT-03 functionality on the GST portal cannot be a valid reason to deny legitimate Input Tax Credit (ITC) claims. This issue has been addressed in several court rulings, providing relief to taxpayers facing unjust ITC denials. The core issue arises when taxpayers attempt to rectify incorrectly paid taxes through Form GST PMT-03, a function sometimes unavailable on the GST portal. Tax authorities have been known to deny ITC claims, citing discrepancies in tax payments, even when the taxpayer has attempted to correct errors. This stance has been challenged, with courts emphasizing that the absence of a functional PMT-03 cannot penalize taxpayers who have genuinely tried to comply with GST regulations. The consequence of these rulings is that tax authorities must now re-evaluate ITC claims rejected solely on the basis of PMT-03 unavailability, potentially leading to significant refunds for affected businesses.
Section 16 of the CGST Act, 2017 outlines the eligibility and conditions for claiming Input Tax Credit. Rule 36(4) specifies documentation requirements. Denying ITC solely due to a system malfunction like PMT-03 absence contradicts the intent of Section 16, potentially leading to legal challenges and penalties for tax authorities.
Tax authorities may attempt to conduct detailed audits to verify the genuineness of transactions where PMT-03 issues were cited. Businesses should maintain meticulous records of all transactions, payment attempts, and communications with the GST portal. A proactive approach to documentation can mitigate potential disputes and ensure compliance.
This ruling protects businesses from unjust ITC denials due to technical glitches on the GST portal, ensuring fair tax administration. It also sets a precedent against penalizing taxpayers for system-related issues.