Challenge to Section 16(2)(c) of GST Act: Coercive Action Stayed

By | February 13, 2025

Challenge to Section 16(2)(c) of GST Act: Coercive Action Stayed

Summary in Key Points:

  • Issue: Is Section 16(2)(c) of the GST Act, which denies ITC to a recipient if the supplier fails to pay tax, constitutionally valid?

  • Facts: The petitioner challenged the validity of Section 16(2)(c), arguing that it unfairly penalizes bona fide purchasers who have paid GST to their suppliers, even if the supplier defaults on remitting the tax to the government. The petitioner pointed out that a similar challenge is pending before the same High Court.

  • Decision: The court listed the matter for hearing and ordered a stay on any coercive action against the assessee until the matter is decided.

Important Note: This interim order reflects the court’s recognition of the potential hardship caused by Section 16(2)(c) to businesses that may lose ITC due to their supplier’s default, even if they have fulfilled their tax obligations. By staying coercive action and listing the matter for hearing, the court indicates its intent to examine the constitutional validity of this provision and its impact on bona fide taxpayers. This case highlights an ongoing debate regarding the fairness and practicality of denying ITC to recipients based on the actions of their suppliers.

HIGH COURT OF PUNJAB & HARYANA
Bobieri Creazon Fashion Accessories (P.) Ltd.
v.
State of Haryana
Sanjeev Prakash Sharma and SANJAY VASHISTH, JJ.
CWP-34258 of 2024
DECEMBER  18, 2024
Mukul Singla, Adv. for the Petitioner. Ms. Mamta Singla Talwar, DAG for the Respondent.
ORDER
1. Learned counsel for the petitioner submits that similar matters are pending before this Court wherein challenge has been made to section 16(2)(c) of the GST Act, 2017 which leaves the fate of a bona fide purchaser having paid his tax in hands of the original supplier who may have defaulted in not paying of the taxes.
2. Notice of motion.
3. Ms. Mamta Singla Talwar, DAG, Haryana accepts notice on behalf of State and seeks time to file reply. May do so, on or before the next date of hearing with a copy in advance to the counsel opposite.
4. Counsel for the petitioner orally prays for allowing him to implead the Union of India as a party. He may file his amended memo of parties. Said prayer of the petitioner is allowed.
5. List again on 06.03.2025.
In the meanwhile, no coercive steps to be taken against the petitioner.
Category: GST

About CA Satbir Singh

Chartered Accountant having 12+ years of Experience in Taxation , Finance and GST related matters and can be reached at Email : Taxheal@gmail.com