#Rule 86A

The Delhi High Court held that input tax credit blocked under Rule 86A cannot be used to satisfy the mandatory pre-deposit under Section 107(6) for filing a GST appeal. The court granted the petitioner four weeks from the judgment date to file the appeal with interim protection from coercive recovery.

The Calcutta High Court held that, under Rule 86A CGST, GST authorities must provide a pre-decisional hearing before blocking a taxpayer’s Electronic Credit Ledger, reinforcing natural-justice safeguards. Accordingly, the order freezing Rs 4.43 crore of input tax credit was set aside, restoring the petitioner’s right to claim ITC and signalling that tax officials must follow due-process before restricting credit.