Input tax credit blockage under Rule 86A upheld where records showed non-genuine invoices and adequate reasons to believe

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....Rule 86A permits blocking of input tax credit only when there is adequate material supporting reasons to believe that credit was fraudulently availed or otherwise ineligible, and a revocation representation must be decided by a reasoned speaking order. On the facts discussed, the blockage was sustained because the order recorded that the suppliers lacked physical infrastructure, CCTV verification did not show vehicle movement, and inward slips suggested manipulation of records. The restriction was confined to credit linked to the questioned transactions and was found not disproportionate, though the Revenue was expected to pursue the consequential show-cause and adjudication without delay.....