Post-decisional hearing for blocked electronic credit ledgers requires reasoned review of disputed input tax credit claims

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....Blocking an Electronic Credit Ledger may be based on reasons to believe that input tax credit was fraudulently availed or is ineligible, including where suppliers are alleged to be non-existent or their registrations cancelled. Even where such statutory conditions are prima facie met, audi alteram partem requires a post-decisional hearing. The affected taxpayer must be allowed to submit a detailed representation and supporting records to substantiate the credit claim. The competent authority must grant a personal hearing and issue a reasoned, speaking determination independently of prior observations, without merits being conclusively adjudicated at the blocking stage.....