Schneider Infra appeal rejected in FY18 ITC case, penalty upheld

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Reviewed by
Shriram SScanX News Team
Key Highlights
  • Schneider Electric Infrastructure's appeal against FY18 ITC claim rejected by Joint Commissioner, CGST
  • Total quantified liability stands at ₹10.08 lakh, comprising ₹5.04 lakh demand and equal penalty
  • Authorities cited violation of Section 140(5) for recording invoices beyond prescribed period
  • Company states no material impact on financials or operations; evaluating legal remedies
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Schneider Electric Infrastructure Limited has received an order rejecting its appeal against a tax demand related to excess Input Tax Credit (ITC) claims for FY18. The Joint Commissioner, CGST & CX, Kolkata Appeal-I Commissionerate, upheld the original penalty of ₹5.04 lakh, bringing the total quantified liability to ₹10.08 lakh plus applicable interest.

The dispute stems from transitional input tax credit of ₹5.04 lakh claimed by the company under Form GST TRAN-1 for FY18. Authorities alleged that three invoices were recorded in books on July 31, 2017, exceeding the prescribed period under Section 140(5) of the CGST Act, 2017, without an extension granted by competent authority.

Order Details and Financial Impact

The appellate authority confirmed the findings of the adjudicating authority regarding the inadmissibility of the credit. The order upholds the demand for the principal amount, consequential interest, and the penalty imposed under Section 122(2)(b) of the CGST Act.

Particulars Details
Authority Joint Commissioner, CGST & CX, Kolkata
Period FY18
Principal Demand ₹5.04 lakh
Penalty ₹5.04 lakh
Total Quantified Liability ₹10.08 lakh plus interest
Date of Knowledge October 17, 2026

Company Response

Schneider Electric Infrastructure stated that there is no material impact on its financials, operations, or routine business activities. The company noted that the impact is limited to the extent of the liability specified in the order. Management is currently evaluating the order and considering appropriate legal remedies.

What the Numbers Show

The rejection highlights a strict enforcement stance on transitional credit timelines. While the absolute financial exposure of ₹10.08 lakh is immaterial to the company's broader balance sheet, the ruling reinforces the regulatory position that recording invoices beyond the statutory deadline without formal extension renders such credits inadmissible, regardless of the underlying transaction's validity.

Historical Stock Returns for Schneider Electric Infra

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Will Schneider Electric Infrastructure pursue further legal remedies in the High Court or Supreme Court, and what is the typical success rate for such appeals regarding GST transitional credit deadlines?

How might this strict enforcement precedent influence the compliance strategies of other companies with pending or unresolved FY18 transitional credit claims?

Are there signs that tax authorities are intensifying audits on historical GST transitional credits, potentially leading to a wave of similar demands across the infrastructure sector?

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Schneider Electric Infra loses CGST appeal, ₹3.25 Cr demand upheld

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Reviewed by
Naman SScanX News Team
Key Highlights
  • CGST Appeals Authority upheld ₹3.25 crore tax demand against Schneider Electric Infrastructure
  • Penalty of ₹0.32 crore also confirmed for FY22 Input Tax Credit discrepancies
  • Company states no material impact on financials or operations from the order
  • Schneider Electric is evaluating legal remedies following the appeal dismissal
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Schneider Electric Infrastructure Ltd has received an order from the Commissioner (Appeals), CGST & Central Excise, Vadodara, upholding a tax demand of ₹3.25 crore and a penalty of ₹0.32 crore. The appellate authority disallowed the company’s appeal against an earlier order regarding alleged excess Input Tax Credit (ITC) claims for FY22.

The order, dated September 28, 2026, confirms the liability originally imposed by the Additional Commissioner, CGST & Central Excise, Vadodara-I Commissionerate, in December 2025. The dispute centers on discrepancies between ITC claimed in Form GSTR-3B and that reflected in Forms GSTR-2A/2B under heads such as "All Other ITC" and "Import of Goods".

Regulatory action and financial impact

The Appellate Authority held that Schneider Electric failed to satisfactorily substantiate or reconcile the disputed differences with corroborative documentary evidence. Consequently, the demand was upheld under Section 73(9) of the CGST Act, 2017, along with consequential interest and penalty.

The company stated that there is no material impact on its financials, operations, or routine business activities. The financial impact will be limited to the extent of the liability as per the order. Schneider Electric is currently evaluating the order and appropriate legal remedies.

Particulars Details
Authority Commissioner (Appeals), CGST & Central Excise, Vadodara
Order Date September 28, 2026
Tax Demand ₹3.25 crore
Penalty ₹0.32 crore
Period Under Dispute FY22
Reason Excess ITC claim vs GSTR-2A/2B

What the numbers show

The total confirmed liability stands at approximately ₹3.57 crore (tax plus penalty). This amount represents a specific regulatory exposure for FY22 rather than a broader operational issue, as the company explicitly noted no material impact on ongoing business activities. The penalty component constitutes roughly 10% of the principal tax demand, indicating a standard statutory consequence for non-compliance rather than an aggravated fraud charge.

Historical Stock Returns for Schneider Electric Infra

1 Day5 Days1 Month6 Months1 Year5 Years
-0.56%-2.85%-2.98%+16.15%+39.50%0.0%

Will Schneider Electric Infrastructure Ltd proceed to the High Court or Appellate Tribunal, and what is the expected timeline for those proceedings?

How might this adverse ruling influence the company's internal GST compliance protocols and ITC reconciliation processes for FY23 and beyond?

Are there indications that tax authorities are intensifying scrutiny on GSTR-3B versus GSTR-2A/2B mismatches across the broader industrial infrastructure sector?

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