Input tax credit eligibility requires proof of receipt and movement of goods; Rule 86A relief does not bar assessment scrutiny.

Input tax credit was denied where the assessee failed to prove receipt and movement of goods through supporting transport and related records. The Court held that the claim under the GST framework depends on satisfaction of the statutory condition that goods or services were actually received, and accepted the assessing authority's factual finding that the documents did not establish genuineness of the transactions. It also clarified that an earlier order under Rule 86A unblocking the electronic credit ledger does not prevent independent examination of ITC eligibility in assessment; any omission to refer to that order was only an irregularity and did not vitiate the assessment.

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Issues: Whether the assessment order disallowing input tax credit on the ground that the petitioner had not established receipt and movement of goods was liable to be interfered with, and whether the prior order under Rule 86A unblocking the credit ledger barred the assessing authority from taking a contrary view in assessment.

Analysis: The claim for input tax credit depended on satisfaction of the statutory condition that the goods or services had in fact been received. The assessing authority examined the materials produced, including bank statements and connected returns, and held that the documents did not establish movement of goods or the genuineness of the transactions. The Court accepted that an earlier order under Rule 86A lifting the restriction on the electronic credit ledger did not curtail the power of assessment under the Act. The omission to refer to that earlier order in the assessment order was treated as an irregularity, but not one that vitiated the assessment. Since the issue turned on factual proof of movement and receipt of goods, and the petitioner had not furnished the supporting transport and related records called for, interference was not warranted.

Conclusion: The assessment denying input tax credit was upheld, and the challenge failed.

Final Conclusion: The writ petition was dismissed, with liberty to pursue the statutory appeal in accordance with law.

Ratio Decidendi: An order under Rule 86A lifting a restriction on the electronic credit ledger does not preclude an assessing authority from independently examining eligibility for input tax credit, and the assessee must prove receipt and movement of goods to sustain the claim.

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