Blocked electronic credit cannot fund appellate pre-deposit until Rule 86A restrictions are lifted through a reasoned unblocking process.
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....Blocked electronic credit ledger balances cannot be utilised for an appellate pre-deposit while a valid debit restriction under Rule 86A remains in force. Section 49(4) permits electronic credit ledger utilisation towards output-tax liabilities only subject to prescribed conditions and restrictions; it does not create an absolute right to use blocked credit. Rule 86A operates as a provisional measure requiring written reasons and permits unblocking when the grounds for restriction cease. Pending unblocking requests require expeditious consideration, with a reasoned order and reasonable opportunity where rejection is proposed.....
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