GST return default can justify e-way bill blocking under Rule 138E, with unblocking tied to regularisation and statutory remedies.

Admitted tax default and failure to file mandatory GST returns justified restriction on e-way bill generation under Rule 138E of the CGST Rules, 2017, which applies where prescribed returns remain unfurnished for the stipulated period subject to limited relaxation. The petitioners were directed to pursue their statutory appeals against the assessment orders and regularise the default before seeking unblocking. The challenge to the blocking action was not accepted, and the relief sought was denied.

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Issues: Whether the blocking of GST registration / restriction on e-way bill generation could be interfered with in view of the petitioners' admitted tax default and non-filing of returns.

Analysis: The petitioners admitted that tax dues arising from assessment orders for the relevant periods had not been paid and that mandatory returns had not been filed. Rule 138E of the Central Goods and Services Tax Rules, 2017 was relied upon to show that a registered person who has not furnished the prescribed returns for the stipulated period is subject to restriction on furnishing information for e-way bill generation, subject to the limited relaxation mechanism provided in the rule. The petitioners were left to pursue their statutory appeals against the assessment orders in accordance with law and to take steps to regularise the default so as to seek unblocking.

Conclusion: The challenge to the blocking action was not accepted, and the petitioners were not granted the relief sought.

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