HC: Rule 117 intra-vires GST Act, cites transitional-credit cut-off date as 'mandatory', not 'directory', follows Nelco

Madras HC dismisses assessee’s plea to declare Rule 117 of CGST Rules, 2017 as ultra vires Section 140 and direct the authorities to permit the Petitioner to file Form GST TRAN – 1 either electronically or manually to claim the transitional ITC; Holds “in the balance, we conclude that the time limit is mandatory and not directory”, remarks “in the context of Transitional ITC, the case for a time limit is compelling and disregarding the time limit and permitting a pa...