Interpreting Rule 86A: Safeguarding Taxpayers' Rights in ITC Blocking

ITC blocking under Rule 86A: restricts orders to credit presently available in the electronic credit ledger, limiting retrospective blockage.

Rule 86A(1) functions as a temporary protective mechanism that may be invoked only where input tax credit is currently available in the taxpayer's electronic credit ledger and the officer has reasons to believe that such present credit has been fraudulently availed or is ineligible; the expression 'amount equivalent to such credit' must be read together with the condition of availability in the ECL and does not authorise retrospective blocking of ITC already utilised or refunded.