Blocking an Electronic Credit Ledger may be based on reasons to...

Blocking an Electronic Credit Ledger may be based on reasons to believe that input tax credit was fraudulently availed or is ineligible, including where suppliers are alleged to be non-existent or their registrations cancelled. Even where such statutory conditions are prima facie met, audi alteram partem requires a post-decisional hearing. The affected taxpayer must be allowed to submit a detailed representation and supporting records to substantiate the credit claim. The competent authority must grant a personal hearing and issue a reasoned, speaking determination independently of prior observations, without merits being conclusively adjudicated at the blocking stage.