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9. The learned counsel further submitted that if there is a discrepancy in the GSTR-1 with the GSTR-3B, the various High Courts have permitted corrections, if there was a human error and this very aspect have already been affirmed by the Supreme Court in the case of Central Board of Indirect Taxes and Customs Vs. M/s. Aberdare Technologies Private Limited and Others reported in 2025 (4) TMI 101. He further submitted that based upon the said judgment passed by the Supreme Court, various High Courts have also followed the said principles and in that regard, has placed before this Court the judgment of the Madras High Court in the case of The Principal Chief Commissioner of GST and Central Excise, The Page No.# 9/24 Superintendent of GST, Goods and Services Tax Network (GSTN) Vs. Deepa Traders reported in 2025 (4) TMI 1009. On the basis of the said, the learned counsel for the Petitioner therefore submitted that instead of rejecting the Petitioner's GSTR-3B on the discrepancy with the GSTR-1, the Respondent No.7 ought to have sought the Explanation from the Petitioner and if satisfied permitted the Petitioner to make the correction in the GSTR-1.

15. In the foregoing paragraphs of the instant judgment, this Court categorically noted two reasons on which the impugned order dated 30.04.2024 is based upon. The first reason pertains to mismatch between the GSTR-1 and GSTR-3B. This Page No.# 12/24 Court had quoted the Table which has been mentioned at Paragraph No.93 of the writ petition in the foregoing paragraphs of the instant judgment. There appears to be no contradiction between the contents of the said Table with what has been mentioned at paragraph No.2.3.I of the impugned order dated 30.04.2024 more so when it is the self- admission on the part of the Petitioner that the Petitioner while submitting the GSTR-1 which pertains to statement of outward supplies the rate of tax mentioned against the four invoices were 18%. It is the specific case of the Petitioner that it was on account of a human error that in the outward supplies in the GSTR-1 return tax rate at 18% was mentioned in the four invoices, though the rate of tax was mentioned as 12% in the actual invoices. Further to that, there was a wrong mention of Credit Note in the GSTR-1 which should have been actually deducted from the invoice value and this aspect was duly reflected in the GSTR-3B as well as in the GSTR-9F. It was the case of the Petitioner that if an Explanation was sought for by giving an opportunity, the Petitioner would have explained before the Respondent No. 7.

"4. The petitioner, Central Board of Indirect Taxes and Customs, must re- examine the provisions/timelines fixed for correcting the bona fide 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 and 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 Page No.# 14/24 exercise our discretion and dismiss the special leave petition."