Tax arrears cannot be enforced by blocking TIN access or denying way-bills; statutory facilities must be regulated by law.

Tax arrears cannot be recovered by blocking a dealer's TIN or denying access to online issuance of C Declaration Forms and way-bills when payment of arrears is not a lawful condition for those facilities. The Court treated such denial as an improper extra-legal coercive measure and held that the dealer's request for unblocking had to be considered in accordance with law. The respondents were directed to decide the representation forthwith and restore access for statutory forms, while the revenue authorities remained free to pursue recovery through lawful means.

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Issues: Whether blocking the dealer's TIN and denying access to the online facility for issuance of C Declaration Forms/way-bills could be used as a method to compel payment of tax arrears, and whether the authority was required to consider the dealer's representation seeking unblocking of the TIN.

Analysis: The dealer was facing tax recovery proceedings, but the Court held that denial of way-bills was not the proper means to recover arrears. Relying on the earlier view that payment of tax was not a prescribed condition for issuance of way-bills and that extra-legal steps cannot be used to coerce payment, the Court found that blocking the TIN for that purpose was not proper. The Court therefore treated the dealer's request for unblocking as a matter requiring consideration in accordance with law.

Conclusion: The blocking of the TIN to prevent issuance of C Declaration Forms/way-bills was held improper, and the respondents were directed to decide the petitioner's representation forthwith in accordance with law.

Final Conclusion: The writ petition succeeded only to the limited extent of securing consideration of the representation and release of access for the statutory forms, while leaving the revenue authorities free to pursue recovery in accordance with law.

Ratio Decidendi: Tax arrears cannot be recovered by denying statutory way-bills or similar facilities when such denial is not a lawful condition for issuance of those forms.

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