Post-determination recovery under the CGST Act extends to negative blocking of an electronic credit ledger. The recovery framework permits multiple recovery modes and is distinguished from provisional credit restrictions, which operate before liability is determined. An interim direction keeping recovery proceedings in abeyance is confined to preventing debits from ledger balances for recovery and does not, by itself, displace a pre-existing ledger-blocking measure. Accordingly, interim protection against recovery debits does not invalidate existing negative blocking, which remains available as a recovery measure after determination of liability.

Section 49(4) permits electronic credit ledger balances to be used for output-tax payments only in the prescribed manner and subject to prescribed conditions and restrictions. Although such credit may ordinarily be used towards liabilities including an appellate pre-deposit under Section 107, that facility is unavailable while a valid Rule 86A credit-blocking order remains in force. Rule 86A operates as a provisional measure, requires recorded reasons, allows an application for unblocking, and cannot continue beyond one year. Blocked electronic credit ledger amounts therefore cannot be utilised for appellate pre-deposit during the blocking order's operation.

Rule 86A permits protective blocking of an Electronic Credit Ledger where material prima facie supports a belief that suppliers are non-existent and their registrations have been cancelled. To preserve audi alteram partem, the affected taxpayer must receive a post-decisional personal hearing and independent, reasoned consideration of documentary material supporting the input-tax-credit claim. The taxpayer must submit a representation, which the competent authority must decide through a reasoned order after granting a personal hearing.

Uploading a show-cause notice only under the portal's 'Additional Notice and Orders' tab, without separate intimation, may deny the taxpayer an effective opportunity to reply and breach principles of natural justice. Where this prevents participation in adjudication, the notice and resulting adjudication cannot be sustained. The appropriate corrective process requires fresh notice, an opportunity to file a reply, a personal hearing, and reasoned adjudication.

Availability of a functional GST Appellate Tribunal restores the statutory appellate remedy under Section 112 where a writ petition was entertained solely because the Tribunal was non-functional. The petitioner must pursue the statutory appeal before the GST Appellate Tribunal, which must entertain the appeal without raising a limitation objection. No merits of the underlying penalty proceedings were adjudicated.

Rule 86A-blocked input tax credit cannot be treated as payment or appropriation towards the statutory pre-deposit under section 107(6), because the restriction prevents debit of that credit for discharging liability. Only credit lawfully available and capable of debit may be used, unless the competent authority removes or modifies the restriction. Rectification of an erroneous FORM GST DRC-07 that caused incorrect portal computation of the pre-deposit supports preservation of the statutory appellate remedy. Appeal filing may proceed upon compliance with the pre-deposit requirement, with electronic assistance and manual filing where portal difficulties continue. Challenges to the tax demand and Rule 86A restriction remain for determination by the competent forum.

Uploading a show-cause notice solely under the portal's "Additional Notice and Orders" tab, without separate intimation, deprived the assessee of an effective opportunity to respond and breached principles of natural justice. The adjudication and appellate orders were therefore unsustainable, particularly because the appellate authority rejected the appeal solely on limitation without examining the merits. The assessee must be permitted to file a reply, be heard, and receive a fresh reasoned determination.

Special Leave Petitions concerning GST proceedings were dismissed, with petitioners retaining liberty to raise all grounds before the GSTAT. They may also seek exclusion of time under Sections 5 and 14 of the Limitation Act, 1963, in pursuing the GSTAT remedy. The writ petition was disposed of as withdrawn.

Further time was granted to pursue the statutory appeal against the tax order. The petitioner may file the appeal within 30 days without objection on limitation. All substantive contentions, including the applicable pre-deposit requirement, remain open for consideration in the statutory appeal.

Alternative efficacious statutory remedy under the Central Goods and Services Tax Act, 2017 is addressed as a bar to entertaining a writ petition where a statutory appellate route remains available. The petitioner's substantive contentions are intended for examination by the appellate authority in accordance with law. The discussion also identifies a limited period for filing the statutory appeal and requires consideration on merits without being influenced by observations made while declining writ jurisdiction.

Alternate statutory remedy was central to the GST challenge against an assessment order issued under Section 74 of the Uttar Pradesh GST Act for financial year 2018-19, raising issues of the Section 6(2)(b) bar and proper-officer jurisdiction. The High Court rejected the writ petition while allowing recourse to the statutory appeal. The Supreme Court declined to entertain the special leave petition but allowed a further 30 days to file the appeal without a limitation objection. All contentions, including the pre-deposit issue in light of payment under parallel Central Act proceedings, remain open.

Blocked input tax credit subject to a subsisting Rule 86A restriction cannot be debited, treated as payment, or appropriated towards the mandatory pre-deposit for a GST appeal. The restriction may be challenged or sought to be modified before the competent forum. An erroneous FORM GST DRC-07 attributable to the adjudicating authority, once rectified, should not deprive the taxpayer of the statutory appellate remedy. Electronic filing of the appeal must be enabled, with manual filing available if portal issues persist, subject to compliance with the prescribed pre-deposit.

Availability of a statutory appellate remedy before the GST Appellate Tribunal requires a challenge to a GST penalty order to proceed through that forum once it becomes functional. A writ petition entertained solely because the appellate forum was non-functional need not continue after the Tribunal is operational. The petitioner may be relegated to the Tribunal with liberty to file an appeal within the stipulated period, and the Tribunal should not object to limitation for the period during which the writ petition was pursued. The appeal is to be decided in accordance with law after considering any interim order.

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.

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.

Post-determination recovery of determined GST dues may include blocking, including negative blocking, of the electronic credit ledger. The interim protection against recovery restricts only debit of credit already lying in the ledger towards recovery; it does not invalidate or suspend a prior ledger-blocking order. Recovery powers extend to prescribed modes involving money or goods under the proper officer's control, third-party recovery, distraint and sale of assets, and assistance from revenue authorities. Rule 86A governs provisional pre-determination blocking and does not limit post-determination recovery action. Electronic credit ledger blocking therefore remains permissible, subject to the protection against debit of available credit during the interim stay.

Interim protection from arrest during a GST investigation was granted to a person summoned in connection with alleged GST and input tax credit fraud. The investigating side confirmed that the relevant notices required attendance for interrogation and did not authorise arrest. The person was therefore directed to appear before the Investigating Officer in accordance with the notices, while receiving protection from arrest in the related criminal proceedings. The protection was limited to facilitating interrogation under the issued notices.

Rectification of patent errors in GST proceedings is confined to errors apparent on the face of the record and cannot be used to revisit an original determination on under-declared ineligible input tax credit. Where no apparent error is established and supporting documents were not submitted, rejection of a rectification application remains undisturbed. The taxpayer may challenge the original determination independently in accordance with law, rather than seek substantive reconsideration through rectification.

Rectification of a mistake in apportioning available input tax credit under the SOP was directed through Section 161 of the Telangana Goods and Services Tax Act, 2017. The proper officer must rectify the identified ITC-apportionment error under the applicable SOP. Following the rectification order, the affected party may pursue an appropriate appeal.

Section 260A(2A) of the Income Tax Act does not expressly exclude application of the Limitation Act, declare the High Court functus officio after expiry of the appeal period, or contain restrictive wording barring condonation. Departmental processing, approval, preparation and execution of the appeal memorandum collectively established sufficient cause and bona fide diligence for a short delay. Merits of the proposed appeal should not be examined while deciding limitation, as that would compromise fairness at the admission stage. The delay was condoned, and the income-tax appeal was directed to be registered and listed for admission.