Retrospective ITC Limitation and Relief

Paper by J the app. The Madurai Bench judgment dated 07 January 2026 in M/s Selva Vilas Jewellery v. Superintendent of GST & Central Excise reinforces the legal effect of the retrospective insertion of Section 16(5) into the GST framework. The decision addresses the continued denial of input tax credit solely on limitation grounds under Section 16(4) for the initial GST years. By recognising the overriding and retrospective nature of the amendment, the Court affirms that procedural timelines cannot defeat substantive statutory entitlements. The ruling aligns adjudication with legislative intent to mitigate hardships faced during the transition and pandemic period. It provides authoritative clarity for legacy ITC disputes.