A ₹22 lakh GST demand — reduced to nil
A mid-sized wholesale distributor in the FMCG sector, GST-registered across two states, with monthly turnover in the ₹1–2 crore range and a lean in-house accounts team. The business had no dedicated litigation support when the notice arrived.
The GST department issued a Section 73 show-cause notice alleging excess Input Tax Credit of roughly ₹22 lakh, driven by a GSTR-2A vs GSTR-3B mismatch. Several suppliers had filed late, so genuine credit appeared "unmatched" on the portal. A short reply window and the risk of interest and penalty made it urgent.
- 1Reconciled GSTR-2A/2B against purchase books line-by-line to isolate genuinely mismatched invoices.
- 2Collected supplier invoices, e-way bills, bank proofs and later-filed returns evidencing the credit.
- 3Drafted a documented reply citing Section 16 conditions and relevant case law on supplier default.
- 4Represented the client at the personal hearing and answered the officer's queries on record.
After the reply and hearing, the officer accepted that the credit was legitimate and dropped the demand. No interest or penalty was levied, and the client walked away with a clean reconciliation process to prevent a repeat.