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    Specified authority approval after three years is jurisdictional; approval from an incorrect authority invalidates reassessment proceedings entirely.
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Rule 86A is confined to blocking input tax credit only up to the...

Rule 86A cannot be used for negative blocking of the electronic credit ledger; blocked credit must be restored.

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GST May 12, 2026 Case Laws HC
Rule 86A is confined to blocking input tax credit only up to the credit available in the electronic credit ledger and does not authorise negative blocking. The text notes that the power must be exercised only after satisfying the statutory preconditions, including a reason to believe and recorded reasons, because otherwise the invocation is vulnerable to challenge on natural justice grounds. Applying that position, the impugned blocking beyond the available balance was held unsustainable, and restoration by unblocking to the extent blocked was directed, while all other issues were kept open.

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Acts Income Tax