Blocked input tax credit cannot fund an appellate pre-deposit while a valid electronic credit ledger restriction continues.

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....Blocked input tax credit cannot be used for an appellate pre-deposit while a valid Rule 86A restriction prohibits debit of the electronic credit ledger. Section 49(4) permits use of ledger credit towards output-tax payments only subject to prescribed conditions and restrictions; it therefore creates no absolute right to use blocked credit for pre-deposit. Rule 86A operates provisionally, requires recorded reasons for the restriction, and permits an unblocking application when the grounds no longer subsist. The unblocking request must be considered expeditiously, with a speaking order and reasonable opportunity before any proposed rejection.....