After the early years of transition and system stabilisation, GST disputes have settled into recognisable categories. Knowing which category a matter falls into makes it easier to judge how it will proceed and what preparation matters.
Credit denial for supplier default
The largest volume of proceedings concerns input tax credit denied because a supplier did not report the invoice or did not pay the tax. The recipient is asked to reverse the credit even where the supply is genuine and payment has been made.
The preparation that helps in these matters is consistent.
Payment trail from the bank, mapped invoice by invoice
Proof of movement of goods, including e-way bills and transport documents
Evidence that the supplier was registered and active on the date of supply
Correspondence with the supplier taking up the reporting failure
Mismatch based demands
Demands raised on a mechanical comparison between GSTR-3B, GSTR-1 and GSTR-2B are common. Many resolve on a proper reconciliation, but only if the reconciliation is presented as a working that ties the two figures together rather than as an assertion that the books are correct.
Orders passed without effective hearing
A recurring ground of challenge is that an order was passed without considering the reply on record, or without granting the hearing that was sought. Section 75(4) requires an opportunity of hearing where an adverse decision is contemplated.
For this ground to be available, the request for hearing must be on record, and the reply must have been filed. Both should be acknowledged, with the acknowledgement retained.
Classification and rate disputes
Classification disputes continue in sectors where products sit near a boundary between entries. These are document heavy matters where technical literature, product composition and end use evidence carry more weight than legal argument alone.
Provisional attachment
Attachment of bank accounts under section 83 has generated a steady stream of challenges. The provision is a protective measure and its exercise requires the formation of an opinion that attachment is necessary to protect revenue. Where that opinion is not recorded, or where the attachment continues beyond the statutory period, the action is open to challenge.
The appellate route and the tribunal
With the appellate tribunal now being operationalised, matters that had accumulated at the first appellate stage have a forum to move to. Businesses carrying older disputes should review them for limitation, pre deposit requirements and the grounds already on record, since the grounds available at the tribunal are shaped by what was pleaded earlier.
Most GST disputes are won or lost on the record built during the first reply, not on the argument advanced three years later.
Practical preparation
Maintain a single dispute register with period, provision, amount, next date and current status.
Keep the reply, the annexures and the acknowledgement together for every proceeding.
Diarise appeal periods from the date of communication of the order rather than the date on the order.
Review recurring issues across periods, since the same allegation often repeats year after year and can be answered once, properly.