Blocking of the electronic credit ledger under Rule 86A was...

Blocking of the electronic credit ledger under Rule 86A was challenged on the ground that the authority neither afforded a pre-decisional hearing nor recorded independent "reasons to believe," instead relying on enforcement reports amounting to borrowed satisfaction. Applying the binding precedent that Rule 86A can be invoked only upon valid, sufficient material forming the officer's own reasons to believe, and that absence of reasons and reliance on another authority's satisfaction is impermissible, the Court held the impugned blocking orders arbitrary and violative of natural justice. The blocking orders for multiple tax periods were quashed and the writ petition was allowed. - HC