Punjab & Haryana High Court Grants Relief to Satyam Auto Components Ltd. for Rectification of GSTR-1 Beyond Limitation Period

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In a recent landmark judgment, the Punjab and Haryana High Court addressed the issue of rectification of Form GSTR-1 beyond the stipulated time limit for filing a refund application.

The case of Satyam Auto Components Ltd. versus Union of India [CWP No. 8019 of 2020, dated October 5, 2023] sheds light on the complexities faced by taxpayers in rectifying errors in their GST returns.


Satyam Auto Components Ltd., engaged in the manufacturing of auto parts, supplied goods to M/s Wabco India Ltd., a SEZ unit. The petitioner filed GSTR-1 in December 2017 and subsequently filed a refund application in April-May 2019. However, an error occurred during the uploading of Statement-4 on the common portal, preventing correction of Form GSTR-1. Despite approaching the GST Help Desk, the petitioner was unable to rectify the form as the last date for revision had passed.

Legal Proceedings:

The petitioner, aggrieved by the inability to correct GSTR-1, filed a writ petition seeking direction to the authorities to allow rectification for filing the refund application.

Court's Decision:

The Punjab and Haryana High Court, in its decision, made the following key observations:

  1. Judicial Precedents: The court relied on the judgment of the Madras High Court in the case of M/s. Sun Dye Chem and the Orissa High Court in the case of M/s Shiva Jyoti Construction. These cases established the precedent of allowing rectification of GST returns beyond the limitation period under specific circumstances.
  2. Technical Dismissal: The court noted that the petitioner’s application for correction of Form GSTR-1 had been dismissed on technical grounds by the Revenue Department. Emphasizing the need for a pragmatic approach, the court held that technicalities should not deprive a taxpayer of their rightful refund.
  3. Facilitation by Revenue Department: Considering the technical hindrances faced by the petitioner, the court directed the Revenue Department to facilitate the uploading of corrected details on the web portal manually. This ensures that taxpayers are not unduly burdened by procedural obstacles.

In a significant decision, the Punjab and Haryana High Court granted relief to Satyam Auto Components Ltd., allowing them to rectify Form GSTR-1 beyond the limitation period. The judgment underscores the court’s commitment to a fair and equitable approach, recognizing the challenges faced by taxpayers in the intricate landscape of GST compliance. This ruling sets a valuable precedent for cases where technicalities impede the correction of GST returns, ensuring that genuine claims for refunds are not denied due to procedural constraints.

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Pooja Gupta

CA Pooja Gupta (CA, ISA, M.com) having 15 years of experience. Educator and Digital Creator

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CA Pooja Gupta (CA, ISA, M.com) having 15 years of experience. Educator and Digital Creator

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