GSTAT says ITC Mismatch Cannot Survive Reconciliation and Actual Reversal

The Revenue sought recovery of ₹53.96 lakh based essentially on the GSTR-3B/GSTR-2A mismatch, but the Tribunal found that the taxpayer's reconciliation and DRC-03 records established reversal of the disputed ITC. 

It also rejected technical objections concerning the DRC-03 and recognised the extended ITC time limit under Section 16(5), while remanding only the question of interest and penalty.