Case Results —
What We Have Recovered,
Defended, and Won.

Client had accumulated IGST refund entitlements across three financial years — shipping bills had been filed but refunds were rejected citing GSTR-1 mismatch and invoice value discrepancies. The client's prior consultant had not pursued the rejection. We filed amended GSTR-1 data, corrected shipping bill details through ICEGATE, and refiled RFD-01 applications with complete reconciliation for each year within the 2-year limitation period.

Client was manufacturing footwear priced below ₹1,000 MRP — attracting 5% GST on output against 12–18% GST on raw material inputs. ITC had accumulated over ₹1.45 crore across the year. Prior refund claims had been rejected twice due to incorrect Net ITC computation — input services were being included in the formula. We recomputed the claim using the amended Rule 89(5) formula with inputs-only Net ITC and the proportionate deduction mechanism, and filed with Statement 1 documentation completed in full.

Client was providing software development services to a US technology company and had been filing refund claims under LUT since 2022. The refund sanctioning officer rejected the claims on the ground that the client was an intermediary under Section 13(8)(b) — since the client coordinated with the US principal's customer in some aspects of delivery. We challenged the classification, established that the client was supplying services on its own account and the coordination was incidental to independent service delivery, and filed a detailed reply with the contract structure and judicial precedents distinguishing intermediary from principal supplier.

Client received Form ADT-01 notice covering two financial years. The audit findings communicated in ADT-02 raised six issues — ITC on ineligible expenses, GSTR-1 vs GSTR-3B output variance, RCM non-discharge on two service categories, and HSN rate misclassification on one product line. We prepared a paragraph-wise reply to each finding with statutory extracts, documentary evidence, and CBIC circular support. The HSN classification finding was defended using CBIC classification circular and a prior AAR ruling from the same state.

Upon receiving ADT-01, client engaged us before the audit commenced. Our rapid pre-audit review identified ₹34 lakh in ITC availed on blocked credit categories (Section 17(5)) across two years that were likely to be raised as findings. We advised voluntary payment of the tax and interest before the audit commenced — under which no penalty is applicable. The voluntary payment was made in full with interest computed precisely for each period.

Client received a Section 73 SCN for FY 2018–19 — the notice was issued in January 2024, which we computed to be beyond the 3-year limitation period measured from the due date of the GSTR-9 annual return for FY 2018–19. The SCN was for alleged wrongly availed ITC on construction materials. We led the reply with the limitation ground under Section 73(10) — establishing the exact due date of the annual return and demonstrating that the SCN issuance date fell outside the permissible 3-year window.

Client had not discharged RCM on GTA (Goods Transport Agency) services and security services across three financial years. Department raised demand of ₹1.1 crore including penalty under Section 74 (fraud allegation). We challenged the Section 74 invocation — non-discharge of RCM due to a misunderstanding of applicability is not fraud. On merits, GTA liability was accepted. Security services RCM challenged on the basis of exemption notifications applicable to the specific arrangement. Voluntary payment of GTA liability with interest was made before reply.

Adjudicating authority had confirmed a demand for ₹44 lakh ITC wrongly availed on works contract inputs — holding that ITC on materials used in works contract services is blocked under Section 17(5)(c). Client had used the materials in construction of commercial property for a business client — not in the construction of his own immovable property. We filed an appeal under Section 107, arguing that the Section 17(5)(c) restriction applies only to ITC on construction for the taxpayer's own account — not on inputs used in a taxable works contract supply to another registered person.

Client had obtained a sanctioned refund of ₹92 lakh for export of services under LUT. Six months after sanction, the department filed an appeal before the Appellate Authority — contending that the client was an intermediary under Section 13(8)(b) and the refund should not have been granted. Client was unaware that the department had filed an appeal and came to us after receiving notice of the hearing. We filed a comprehensive counter, reiterated the classification arguments, and relied on the GSTN portal evidence, contract terms, and FIRA documentation.

An NRI based in UAE who held advisory roles with two Indian companies — receiving monthly advisory fees — came to us after one of the Indian companies received a GST audit notice. Our review established that the Indian companies had not discharged RCM on the advisory fees paid to the NRI over four years. The total RCM liability with interest across both companies for four years was computed at ₹18.2 lakh. We structured a voluntary compliance plan — both companies paid the RCM with interest and filed amended GSTR-3B returns before the audit progressed further.

Client engaged us for an annual GST Health Check before GSTR-9 filing. Our review identified ₹41 lakh of ITC availed on ineligible expenses across the year — primarily food and beverage expenses classified under blocked credits, and ITC on vehicle maintenance availed in full without applying the business use restriction. Separately, the review identified ₹22 lakh of unclaimed ITC refund on export of goods that the client was entitled to but had not claimed — still within the 2-year limitation window.