The Madras High Court (Madurai Bench) answered this in the Periyasamy Karthikeyan case (Order dated 06.01.2026).
The taxpayer had mistakenly claimed ITC under CGST/SGST instead of IGST in GSTR-3B. The error was disclosed in GSTR-9 and certified in GSTR-9C. After scrutiny, the department accepted the explanation and issued ASMT-12.
Later, Fresh proceedings under DRC-01A and DRC-01 were initiated on the same issue. The Court held this impermissible, replying on Section 16(2) which bars further action once explanation is excepted.
The Court also noted that it was merely a head-classification error and there was no revenue loss.
A key ruling reinforcing finality of scrutiny proceedings and protecting taxpayers from repeated actions under GST.
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