The court held that input tax credit for FY 2019-20 cannot be denied if the GST return was filed before 30 November 2021, as Section 16(5) of the CGST Act overrides the earlier time limit.

The tribunal dropped the demand for PGP, holding it exempt under Notification No. 9/2016-ST and clarificatory circulars. However, it confirmed service tax liability for PGPPM, PGPEM, and EPGP.

The Bench stated that at this stage the dispute was only at the level of seizure and provisional release, while final determination on legality of import and valuation could proceed before the adjudicating authority.