Central Board of Indirect Taxes and Customs vs. M/s Aberdare Technologies Pvt. Ltd. & Ors.
Date of Judgment: 21 March 2025
The Supreme Court dismissed the Special Leave Petition filed by the Central Board of Indirect Taxes and Customs, upholding the Bombay High Court’s judgment. The Court found the High Court’s judgment fair, noting no loss of revenue.
The Supreme Court emphasized the need for realistic timelines and provisions to correct genuine clerical or arithmetic errors, stating such corrections stem from the fundamental right to do business. Denying correction based solely on software limitations was deemed inadequate, as software should be configured to facilitate compliance, not hinder it. The judgment highlighted the unnecessary hardship caused to purchasers denied input tax credit despite having already paid the taxes due, effectively causing double payments.
The Court recommended re-examination of relevant provisions to ensure reasonable allowances for correcting human errors in tax filings. It also noted disagreement with certain prior judgments (Bar Code India Ltd. v. Union of India and Yokohama India Pvt. Ltd. v. State of Telangana), suggesting these cases did not represent appropriate legal principles in this context.