Scope of Rectification under Section 161 of the CGST Act is Confined to Errors Apparent on the Face of Record

The Hon’ble Madras High Court in Scals Enterprises v. The Commercial Tax Officer [W.P. No. 22391 of 2026 dated June 23, 2026] upheld the rejection of the rectification application filed under Section 161 of the Central Goods and Services Tax Act, 2017 (“the CGST Act”) insofar as it pertained to under-declaration of ineligible Input Tax Credit (“ITC”) and held that the scope of Section 161 of the applicable GST enactments is confined to rectification of patent errors and where the order sought to be rectified does not suffer from any error apparent on the face of the record, the rectification application cannot be entertained. However, liberty was granted to the Assessee to assail the order in original in accordance with law.

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