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        2026 (2) TMI 651 - HC - GST

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        Re-blocking of Electronic Credit Ledger challenged as time-barred; court upholds re-blocking as compliant with Rule 86A. Challenge to re-blocking of an electronic credit ledger alleged it exceeded the permissible period under Rule 86A and was void for want of jurisdiction. ...
                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.

                              Re-blocking of Electronic Credit Ledger challenged as time-barred; court upholds re-blocking as compliant with Rule 86A.

                              Challenge to re-blocking of an electronic credit ledger alleged it exceeded the permissible period under Rule 86A and was void for want of jurisdiction. The court found an earlier tax demand and penalty order had been passed and the ledger was re-blocked within the one-year period prescribed by Rule 86A; the petitioner had not disclosed these material facts in the writ petition. Because statutory proceedings were ongoing and the time limit under Rule 86A remained unexpired, the administrative blocking was lawful and the writ petition was dismissed.




                              Issues: Whether the re-blocking of the petitioner's Electronic Credit Ledger on 30.05.2025 was liable to be quashed on the ground that it remained blocked beyond the permissible period under Rule 86A of the Central Goods and Services Tax Rules, 2017 and was void for want of jurisdiction or statutory violation.

                              Analysis: The respondents produced an order-in-original dated 01.05.2025 arising from proceedings under Section 74 of the Telangana Goods and Services Tax Act, 2017 in which tax, interest, fee and penalties aggregating Rs. 4,95,64,354/- were imposed and, following that order, the Electronic Credit Ledger was re-blocked on 30.05.2025. The period of one year specified by Rule 86A of the Central Goods and Services Tax Rules, 2017 had not expired since the date of the re-blocking. The writ petition filed in July, 2025 did not disclose these material facts, including initiation of proceedings under Section 74 of the TGST Act, which were germane to the challenge to the blocking. In the context of a writ petition, material facts relevant to the cause of action must be disclosed. Given the ongoing statutory proceeding and the unexpired one-year period under Rule 86A, there was no ground to interfere with the administrative action of blocking the Electronic Credit Ledger.

                              Conclusion: The challenge to the re-blocking of the Electronic Credit Ledger is rejected; the writ petition is dismissed and the respondents' action in re-blocking the Electronic Credit Ledger on 30.05.2025 is upheld (in favour of Revenue).


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                              ActsIncome Tax
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