(i) The Central Board of Indirect Taxes and Customs must re-examine the provisions/timelines fixed for correcting the bonafide errors. Time lines should be realist as lapse/defect invariably is realized when input tax credit is denied to the purchaser when benefit of tax paid is denied. Purchaser is not at fault, having paid the tax amount. He suffers because he is denied benefit of tax paid by him. Consequently, he has to make double payment. Human errors and mistakes are normal, and errors are also made by the Revenue. Right to correct mistakes in the nature of clerical or arithmetical error is a right that flows from right to do business and should not be denied unless there is a good justification an d reason to deny benefit of correction. Software limitation itself cannot be a good justification, as software are meant ease compliance and can be configured. Therefore, we exercise our discretion and dismiss the special leave petition.

(ii) Decisions of the High Courts in Bar Code India Limited v. Union of India and others (2024) SCC OnLine P&H 13853 and Yokohama India Private Limited v. State of Telangana (2023) 108 GSTR 115”, prima facie, do not lay down good law in this regard. Ratio therein may be examined in another case.