The Delhi High Court held that ITC cannot be denied merely due to a clerical error in mentioning the wrong GSTIN in invoices when the transaction is genuine and no double credit is claimed.

B. Braun Medical India Pvt. Ltd. vs. Union of India (2025: DHC:1656-DB W.P. (C) 114/2025 & CM Appl. 434/2025)

1. Brief Facts

• The Petitioner claimed Input Tax Credit (ITC) on purchases where invoices reflected an incorrect GSTIN (Bombay GSTIN instead of Delhi GSTIN).
• The Department denied ITC primarily on the ground of GSTN mismatch under Section 16(2) (aa) of the CGST Act.
• The Department did not dispute that:
  • Goods were actually delivered,
  • Payment was made,
  • The Assessee’s name was correctly mentioned in invoices.
• On a specific query from the Court, the Department admitted that no duplicate ITC claim existed.
• The impugned order dated 28.06.2024 denied ITC solely on account of the incorrect GSTIN mentioned in invoices.

2. Important Key Takeaways

(A) Clerical Error Cannot Defeat Substantive ITC

The Court held that a mere clerical mistake in mentioning GSTIN (Bombay instead of Delhi) cannot result in denial of ITC when the transaction is genuine and all substantive conditions are fulfilled.

(B) Substance Over Technicality

Where:

• Goods were delivered,
• Payment was made,
• ITC was not claimed elsewhere,
• Supplier furnished invoice details in GSTR-1,

denial based purely on GSTN mismatch is unjustified.

(C) Section 16(2) (aa) Interpretation

Section 16(2)(aa) requires invoice details to be furnished by the supplier in GSTR-1. The provision is not intended to penalise recipients for supplier-level clerical errors when transaction authenticity is undisputed.

(D) Relief Granted

The Delhi High Court set aside the impugned order dated 28.06.2024 and allowed the ITC claim.

3. Author’s Comment – Business Impact

This judgment reinforces a critical GST principle: procedural defects cannot override substantive compliance.

Practical Implications:

• Minor clerical errors in GSTIN mentioning should not automatically result in ITC denial.
• Revenue authorities must examine transaction genuineness rather than mechanically relying on GSTN mismatches.
• Strengthens protection for bona fide recipients against supplier-level documentation errors.
• Reduces risk of ITC denial in multi-state corporate structures where clerical GSTIN mistakes may occur.

The ruling promotes a pragmatic and business-friendly interpretation of Section 16 and will likely be cited in future GST mismatch disputes.