Maruti Enterprise ITC is not an independent Entitlement

In a significant and detailed ruling, the Court rejects the constitutional challenge to Section 16(2)(c), holding that ITC is a conditional statutory entitlement and not an absolute right. 

Distinguishing earlier VAT jurisprudence, the Court anchors its reasoning in the structural design of GST, particularly its destination-based model and inter-State credit flow. It concludes that linking ITC to actual tax payment is fundamental to maintaining fiscal equilibrium and preventing revenue leakage. 

The judgment decisively tilts the balance in favour of revenue protection while recognising limited hardship to bona fide recipients.