https://www.taxtmi.com/caselaws?id=784335 Blocking of the taxpayer's ECL under Rule 86A CGST Rules was challenged for breach of natural justice and absence of legally sustainable "reasons to believe." Applying HC precedent, the Court held that Rule 86A requires independent, cogent material forming the proper officer's satisfaction and cannot rest on borrowed satisfaction from enforcement reports. As no pre-decisional hearing was granted and the order merely alleged ITC from non-existent suppliers and multiple e-way bills without recording independent reasons to believe, the mandatory prerequisites of Rule 86A were not met. The Rule 86A blocking orders were quashed and the writ petition was allowed. en-us Thu, 11 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 07:51:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784335 Blocking of the taxpayer's ECL under Rule 86A CGST Rules was challenged for breach of natural justice and absence of legally sustainable "reasons to believe." Applying HC precedent, the Court held that Rule 86A requires independent, cogent material forming the proper officer's satisfaction and cannot rest on borrowed satisfaction from enforcement reports. As no pre-decisional hearing was granted and the order merely alleged ITC from non-existent suppliers and multiple e-way bills without recording independent reasons to believe, the mandatory prerequisites of Rule 86A were not met. The Rule 86A blocking orders were quashed and the writ petition was allowed. Case-Laws GST Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784335