Rule 86A of the GST Rules permits only a temporary restriction...

Rule 86A of the GST Rules permits only a temporary restriction on debit of input tax credit actually available in the electronic credit ledger; it does not authorise the Commissioner or an authorised officer to create a negative balance or block credit beyond the amount standing to the taxpayer's credit. Following earlier High Court precedent and aligned decisions of other High Courts, the Court held that availability of credit is a condition precedent for invoking the rule. The negative blocking of the taxpayer's electronic credit ledger was therefore unsustainable, though the authorities were left free to pursue other lawful recovery through statutory remedies.

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