Introduction

The petitioner, M/s Shah Associates, challenged the order dated 23.02.2026 passed by the Assistant Commissioner of Commercial Taxes under Rule 86A of the CGST/KGST Rules, whereby the petitioner’s Electronic Credit Ledger (ECL) was blocked.

The Department alleged that the petitioner had availed Input Tax Credit (ITC) on the basis of fraudulent invoices and, acting on such suspicion, blocked the ITC available in the Electronic Credit Ledger without issuing any prior notice or granting an opportunity of hearing.