Shubham R K and Associates

GST Portal vs GST Law - Who Bears the Risk?

For Feb 2026 (GSTR-3B), the GST portal allowed utilization of SGST credit against IGST liability (after exhausting IGST ITC) even when CGST credit was available.

Many taxpayers filed accordingly because the system permitted it.

However, for the March 2026 return period, the portal appears to have reverted - now forcing CGST utilization first before allowing SGST set-off.

At the same time, an earlier tutorial suggesting flexibility in utilisation sequence was modified.

The key question here is-

If returns are filed based on portal functionality,
can taxpayers later be held liable for “incorrect” utilisation?

This creates a serious compliance gap:

- Law remains constant
- Portal behavior changes
- Clarity is missing

Draft Income-tax Rules, 2026 introduce a key change for PAN allotment.

Birth certificate now mandatory for individuals born on or after 1st October 2023.

A similar condition already applies to passport applications.

Happy Holi 🫟