Section 140 of the CGST Act, 2017 — Transitional Credit - The Petitioner sought quashing of orders reversing the transitioning of TDS under Section 140(1). The court observed that they had considered the identical question in an earlier batch of writ petitions, and vide order dated 26.02.2021, decided the same in favour of the assessees. The Revenue has filed eight applications seeking review of order dated 26.02.2021. The grounds raised in the review applications do even make the slightest pretence of pleading any acceptable ground for review. The sole argument raised and argued relates to the effect and applicability of the proviso to Section 140(1), which has been raised and considered even at the time of original hearing. It is quite evident that the attempt of the State is to re-agitate the same issue as was raised and considered in the original round of litigation. If at all the Department believes that the conclusion arrived at earlier was contrary to the legal position, then review is not the appropriate remedy. The court found no merit in the applications for review and dismissed the same.

Held that:- The Hon’ble High Court allowed the petitions and reiterated the conclusion in order dated 26.02.2021.