Head-wise ITC Mismatch Not Excess Availment

The GSTAT Lucknow ruled that head-wise mismatches in ITC allocation between IGST, CGST, and SGST do not amount to excess availment if the aggregate eligible credit remains sufficient. Applying the “common pool” principle under Rule 88B, the Tribunal held that such discrepancies are revenue neutral, invalidating demands for tax, interest, and penalty.