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‘Admitted Liability’ Auto-Selection on GST Portal Misled Assessee: Madras HC Allows Liberty to File GST Appeal Despite Delay [Read Order]

The petitioner was unaware that the GST portal automatically treats the tax liability as "admitted" unless manually changed to "disputed”, thus caused delay in filing appeal

‘Admitted Liability’ Auto-Selection on GST Portal Misled Assessee: Madras HC Allows Liberty to File GST Appeal Despite Delay [Read Order]
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Due to uncertainty produced by the GSTN interface, the Madras High Court recently ruled that the assessee had the right to appeal a GST (Goods and Services Tax) assessment order even after the statute of limitations had passed. The petitioner, Tvl SLV Concrete had challenged the assessment order dated 08.11.2024 and its corresponding summary order in Form DRC-07, contending...


Due to uncertainty produced by the GSTN interface, the Madras High Court recently ruled that the assessee had the right to appeal a GST (Goods and Services Tax) assessment order even after the statute of limitations had passed.

The petitioner, Tvl SLV Concrete had challenged the assessment order dated 08.11.2024 and its corresponding summary order in Form DRC-07, contending that the default configuration of the GST portal, particularly the automatic selection of "admitted liability" misled the petitioner and hindered timely filing of the appeal.

Justice Krishnan Ramasamy, while delivering the order, observed that the petitioner was unaware that the GST portal automatically treats the tax liability as "admitted" unless manually changed to "disputed."

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The petitioner, acting under this misunderstanding, filed a rectification application instead of an appeal, which was later dismissed on 09.05.2025. The pendency of the rectification application consumed important time, resulting in the expiry of the appeal period.

The petitioner’s counsel, Mr.G.Natarajan, Advocate, submitted the willingness to file an appeal against the impugned assessment order dated 08.11.2024 passed by the respondent and he has restricted his relief and requested this Court to grant liberty to the petitioner to file an appeal against the impugned assessment order since it will be sufficient to meet out the case of the petitioner.

The court, considering the procedural confusion and absence of any legal bar on filing an appeal, permitted the petitioner to file the appeal afresh, subject to the payment of 15% of the disputed tax amount comprising 10% towards the statutory pre-deposit and an additional 5%.

The bench further clarified that the Appellate Authority must not reject the appeal on the ground of delay and should adjudicate the matter on merits after providing a fair hearing to the petitioner.

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