Facts of the Case: The petitioner filed an application seeking refund of excess CGST paid. However, in Form GST RFD-01, the refund amount was mistakenly entered under the IGST head instead of the CGST head, which the petitioner claimed was due to a software glitch.

The adjudicating authority rejected the refund application, and the appellate authority upheld the rejection, holding that the petitioner had filed the refund claim under the wrong head (IGST instead of CGST). Further, the petitioner failed to adduce evidence to substantiate the claim. The petitioner contended that the error was purely technical and that the substantive claim for refund of CGST could not be denied on this ground.

Issue: Whether a genuine claim for refund of CGST can be denied merely due to a technical/clerical error in mentioning the wrong tax head in Form GST RFD-01, without adjudicating the claim on merits.

Held: The High Court held that:

• The petitioner’s refund application clearly claimed excess payment of CGST, and merely citing the wrong head in the form could not be a ground to reject a substantive refund claim.
• Citation of a wrong provision or a typographical/software error in the form cannot deprive a taxpayer of vested rights under the law.
• The appellate authority erred in not adjudicating the claim on merits.
• The finding that the petitioner failed to adduce evidence was also beyond the scope of the show cause notice, thereby violating principles of natural justice.

Accordingly, the impugned orders were set aside and the matter was remitted to the appellate authority for fresh determination in light of the Court’s observations.

Case Name: Bharat Mint & Aroma Chemicals vs. Union of India dated 01.08.2025

To read the complete judgment 2025 Taxo.online 1748