ITC on import of goods and SEZ procurements cannot be denied for FY 2018-19 as GSTR 2A did not capture Import data during impugned period

Last updated: 19 June 2026

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The Karnataka High Court has ruled that Input Tax Credit (ITC) cannot be denied for the financial year 2018-19 simply because import and SEZ procurement data was not reflected in GSTR-2A. The court found that the GSTR-2A system, by design, did not capture such details during that period. Furthermore, the Bill of Entry was sufficient for claiming ITC on imports, and matching with GSTR-2A was not required before January 2022.

Court :
Karnataka High Court

Brief :
The Hon’ble Karnataka High Court in Biocon Limited v. State of Karnataka [Writ Petition No. 11918 of 2024 dated April 30, 2026] allowed the writ petition of the Assessee and quashed the GST demand of Rs. 20.01 Crore raised on the allegation of excess availment of Input Tax Credit ( “ITC” ) on account of mismatch between ITC claimed in Form GSTR-3B and ITC reflected in Form GSTR-2A, holding that during FY 2018-19, Form GSTR-2A by design did not capture details relating to import of goods, import of services and SEZ procurements, thereby rendering the very basis of the demand unsustainable. The Court further held that the Bill of Entry, being the statutory document for availing ITC on imported goods under Rule 36(1)(d) of the CGST Rules, 2017, did not require any matching with GSTR-2A prior to insertion of Section 16(2)(aa) of the CGST Act, 2017 with effect from January 01, 2022.

Citation :
Writ Petition No. 11918 of 2024 dated April 30, 2026

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Attached File : 671907_6014_karnataka_at_bengaluru_biocon_limited.pdf

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Judgement posted by

Bimal Jain

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FCA, FCS LLB with21 Yrs of Experience inTaxation Indirect and Direct: Education Qualification: B.Com (Hons) Chartered Accountants Company Secretary LLB Qualified SAP FI/CO Consultants Professional Membership: Chairmanof Indirect Tax Committee of PHD Chamber of Commerce Member of Indirec ... Read more

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