I have to reverse ITC of Rs. (15000 )I have availed in 2019 pertaining to retrospectivley cancelled dealer who has not filed his 3b which we are ready to pay voluntarily through DRC 03 u/s 73(5) on suggestion of the tax officer during a refund sanction process.

Now  The conflict is regarding Interest on it

My Stand:  I had enough amount available to cover the said ITC in ITC ledger from the period I have availed ITC (2019) to (2021) further at the end of 2022 all ITC was utilized and no balance was left but I further availed ITC in future peiords from 2023 to 2026 which was also enough to conver said reversal amount. So I paid interest for the period of 2019-2022 where i was falling short of balance and further i had enough balance through valid input throughout the priod 

Officer's Stand : I have to pay interest from where I first utlilized all itc   from 2022 to 2026 (i.e when the ITC ledger was totally utilized and after the new inputs were availed ) and those new ITC availed are counted for interest calculation .

 

Plz Guide in this Regard

Thank you