HC: Time-limit for availing transitional-credit not 'ultra-vires', stresses on fiscal management certainty

HC holds that the time limit stipulated under Rule 117 is not ultra vires the CGST Act, 2017, is in consonance with the transitional nature of enactment, and “is neither arbitrary nor unreasonable” as there is no indefeasible right to carry forward CENVAT credit; Observes that said Rule is traceable to the rule-making power conferred u/s 164(2) and credit envisaged u/s 140(1) being a concession, can be regulated by placing a time limit; Remarks “The time limit for avail...