Goods and Service TaxArticle·13 February 2026
Principal Bench’s first order on reconciliation before demand
By JustIDT
Executive Summary
J is delighted to share the synopsis of the first order passed by the Principlal Bench of GSTAT. In the case of M/s Sterling & Wilson Pvt. Ltd. v. Commissioner, Odisha, Commissionerate of CT & GST & Ors., the GSTAT Principal Bench has clarified that mismatches between GSTR-1 and GSTR-3B cannot, by themselves, justify allegations of tax evasion or automatic confirmation of demand. The ruling reinforces the need for proper reconciliation, adherence to statutory procedure, and a clear distinction between proceedings under Sections 73 and 74 of the CGST Act before fastening liability on a taxpayer.
GSTAT Principal Bench: GSTR-1 vs GSTR-3B Mismatch Requires Reconciliation, Not Automatic Demand
Background and Signi...
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