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HINDUSTAN STEEL v. DEPUTY COMMISSIONER OF STATE TAX GOREGAON EAST – BOMBAY HIGH COURT

High Court, Bombay
M.S. Sonak, Justice & Advait M. Sethna, Justice

HINDUSTAN STEEL
v.
DEPUTY COMMISSIONER OF STATE TAX GOREGAON EAST

WRIT PETITION (L) No. 28684 of 2025 dated 16.10.2025

Law : GST
Act Name : Central Goods & Service Tax Act, 2017
Rule Number : Rule 86A
Rule Name : Central Goods & Services Tax Rules, 2017
Decision : In favour of assessee

Negative blocking of electronic credit ledger – Rule 86A of CGST Rules – Petitioner contended powers under Rule 86A restricted to blocking only input credit available in ledger on order date – Respondents argued broader power to block credit to prevent fraudulent availment even beyond existing ledger balance – Rule 86A powers can only be exercised to block credit actually available in Electronic Credit Ledger on date of blocking order – Blocking future or non-existent credit ultra vires – Held: Order set aside – Respondents to restore excess blocked credit within four weeks – Petitioner directed not to use restored credit prematurely – Power to recover fraudulently availed credit remains unaffected.

Represented By:

Counsel for the Petitioner: Vivek Laddha, a/w Aniket Kamtam

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