Answer

1. F

   Facts

   Yes. Rule 86A requires the officer to record reasons in writing before blocking. You can ask for those reasons and a hearing.

2. P

   Provisions and law

   • Rule 86A(1), CGST Rules 2017Commissioner or authorised officer, not below Assistant Commissioner, may disallow debit of ITC for recorded reasons where the supplier or recipient is non-existent, goods were not received, tax was not paid or there is no valid document
   • CBIC guidelines on Rule 86A, 2 November 2021Block must rest on material evidence, not suspicion; amount not more than the suspect credit; monetary limits for officer ranks; taxpayer may give evidence for review
3. A

   Analysis

   Rule 86A(1) says 'for reasons to be recorded in writing'. High Courts, for example the Bombay High Court in Rithwik Projects (2025), have set aside blocks without recorded reasons and required a timely post-decisional hearing. Asking in writing also builds your record if you later need a writ petition. Keep the letter short: GSTIN, block date, amount, and a request for reasons and hearing.

4. C

   Conclusion

   1. 1Draft a one-page letter citing Rule 86A(1) and the block date and amount.
   2. 2Ask for a copy of the recorded reasons and the material relied on.
   3. 3Ask for a personal hearing.
   4. 4Send by email and deliver a physical copy, keeping the acknowledgement.
   5. 5Diary a follow-up date after 7 days.

General guidance from TaxSavvy’s library of money processes. Laws change; your Savvy confirms the answer on your exact case before anything is filed.