Steel Authority of India Ltd. v. State of Jharkhand
Eligibility under the repealed VAT law required examination in that law’s process; the challenged GST-based orders could not stand on the Usha Martin reasoning.
By CA Nikhil Gupta · Reviewed against the retained judgment 2026-09-26
Eligibility under the repealed VAT law required examination in that law’s process; the challenged GST-based orders could not stand on the Usha Martin reasoning. Adjudication and appellate orders quashed; ₹30,29,99,999 with statutory interest to be restored within four weeks, with lawful VAT proceedings reserved.
What happened
State officers reversed about ₹30.30 crore of transitional credit from SAIL’s electronic credit ledger, alleging ineligible input credit originating under the former VAT regime.
Questions before the court
- Could GST proceedings determine the underlying VAT-era eligibility and recover the carry-forward credit?
Why the court ruled this way
Eligibility under the repealed VAT law required examination in that law’s process; the challenged GST-based orders could not stand on the Usha Martin reasoning.
Controlling point
Eligibility under the repealed VAT law required examination in that law’s process; the challenged GST-based orders could not stand on the Usha Martin reasoning.
Order and next steps
Adjudication and appellate orders quashed; ₹30,29,99,999 with statutory interest to be restored within four weeks, with lawful VAT proceedings reserved.
Practical implications
The operative result is case-specific: Adjudication and appellate orders quashed; ₹30,29,99,999 with statutory interest to be restored within four weeks, with lawful VAT proceedings reserved. Apply it within the court’s stated limit: A later Supreme Court petition dismissal is described by the discovery article; the PDF is the earlier High Court judgment and preserves VAT-law remedies.
Limits of this ruling
- A later Supreme Court petition dismissal is described by the discovery article; the PDF is the earlier High Court judgment and preserves VAT-law remedies.
Law and judgment source
- Jharkhand GST Act, 2017, section 140
- Jharkhand VAT Act, 2005
The linked PDF is a complete public court-copy document. The official court portal is provided for independent verification; a stable judgment-specific official link was not independently established. A three-byte UTF-8 transport prefix preceding the PDF signature was removed to make the unchanged PDF content open in standard readers. The discovery article concerns a later Supreme Court proceeding; this note and retained PDF cover the earlier High Court judgment identified here. Verify the later proceeding independently. A three-byte UTF-8 transport prefix before the PDF signature was removed; internal PDF bytes were unchanged.
Source checked: 2026-09-26 · Judgment paragraphs: paragraphs 10–13 · Later case history: later history recorded. A later review or appeal was located; the disclosed subsequent proceeding must be checked for its current outcome.
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