The Telangana High Court has dismissed a writ petition challenging interest of Rs. 4,82,295 levied under Section 50(1) of the CGST Act, holding that mere deposit of the tax amount in the Electronic Cash Ledger does not, by itself, amount to discharge of the corresponding tax liability, and that the liability stands discharged only when the amount is debited from the ECL towards the tax liability upon filing of the GSTR-3B return. The ruling by Chief Justice Aparesh Kumar Singh and Justice G.M. Mohiuddin in WP No. 7789/2024 (M/s Sri Uma Manpower Suppliers, decided 10.09.2026) follows the Division Bench judgment of the Jharkhand High Court in M/s RSB Transmissions (India) Ltd. (decided 18.10.2022) and declines to follow the Madras HC Single Judge’s view in Eicher Motors / Tamil Nadu State Transport Corporation.
The petitioner had deposited amounts totalling Rs. 35,82,368 through two challans on 05.01.2019, credited to the ECL, but the December 2018 liability was actually discharged only upon filing GSTR-3B for September 2019 on 17.10.2019 — a delay of 273 days. The court held that Sections 39, 49 and 50 of the CGST Act and Rule 87 contemplate a statutory distinction between deposit into the ECL and its subsequent utilisation towards a particular tax liability through debit. The ECL operates as a statutory ledger; mere availability of a balance does not identify or appropriate the amount towards any self-assessed liability. The contention that technical glitches prevented filing was held insufficient to alter the statutory consequence. The ruling creates a clear inter-HC conflict with the Madras HC’s view.
- 2026-juristway.com-2706-HC(Telangana)-GST | High Court of Telangana | WP No. 7789/2024 | 10.09.2026
