Rule 39(1)(a) of the CGST Rules requiring distribution of input tax credit available for distribution in a month to be made in the same month must be construed harmoniously with Sections 16 and 20 of the CGST Act as applying only after fulfilment of Section 16(2) conditions, and is therefore not ultra vires – Reliance Jio Infocomm Ltd. Vs. Union of India and Ors. – Madras High Court