Answer

GST

Credit blocked across group firms

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  1. Facts

    Each GSTIN has its own ledger, so each block needs its own reasons. Prepare separate representations, showing which firm actually dealt with the supplier.

  2. Provisions and law

    • Rule 86A(1), CGST Rules 2017Officer not below Assistant Commissioner may disallow debit of ITC, for recorded reasons, to pay any liability or claim any refund, where the credit looks fraudulent or ineligible on listed grounds
    • CBIC guidelines on Rule 86A, 2 November 2021Blocking needs material evidence and is not to be done mechanically or on mere suspicion
  3. Analysis

    Rule 86A blocks a specific ledger for reasons linked to that registered person's credit. If only one firm bought from the supplier, the other two can ask for release on that basis. Example: Firm A bought ₹20 lakh from the supplier; Firms B and C never did. Show B and C's purchase registers and GSTR-2B with no such supplier.

  4. Conclusion

    1. List purchases from the suspect supplier by each GSTIN.
    2. For firms with no purchases, ask for immediate release.
    3. For the firm that bought, give full evidence.
    4. Keep the representations separate.

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