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Supreme Court of India 2023-03-13 allowed

The State of Karnataka vs M/s Ecom Gill Coffee Trading Private Limited

Bench: 2 — M.R. Shah, C.T. Ravikumar

In Brief

This case concerns the burden of proof for claiming Input Tax Credit (ITC) under Karnataka's VAT law. Purchasing dealers claimed ITC on coffee and garment purchases from registered dealers, producing invoices and proof of payment by cheque. The Assessing Officer doubted the transactions' genuineness and disallowed the ITC, which the Appellate Authority upheld. However, the Tribunal and High Court allowed the ITC, relying on the invoices and payments. The Supreme Court reversed, holding that mere invoices and cheques are insufficient. To claim ITC, purchasers must affirmatively prove the transaction's genuineness and actual physical movement of goods, including seller details, delivery vehicle information, freight receipts, and delivery acknowledgments. The burden of proof rests entirely on the purchasing dealer and cannot be shifted to revenue.

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Tax Law Input Tax Credit Burden of Proof Indirect Taxes VAT

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