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As per case facts, the Petitioners' Electronic Credit Ledgers (ECLs) were blocked by Respondents, creating negative balances, due to allegedly fraudulently availed or ineligible Input Tax Credit (ITC). The Petitioners
...argued that these were presumptions and challenged the blocking of their ECLs beyond the available credit. The question arose whether Rule 86-A of the Goods and Services Tax Rules, 2017, permits blocking a taxpayer's ECL by an amount exceeding the credit available when the Order was issued. Finally, the High Court, aligning with previous judgments upheld by the Supreme Court, ruled that Rule 86-A only allows blocking ITC that is *available* in the ECL at the time of the Order, not creating a negative balance. Thus, the impugned Orders were set aside to the extent they disallowed debit from ECLs beyond available ITC, with Respondents retaining liberty for legal recovery.
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