Answer

GST

Does my block hurt my customers

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  1. Facts

    Not directly. Your customers' ITC depends on you reporting their invoices and paying your output tax. If you keep filing and paying in cash, their credit flows as usual.

  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
    • Sec 16(2), CGST Act 2017Conditions for ITC: invoice, receipt, tax paid by supplier, return filed
  3. Analysis

    Rule 86A affects only your ability to use your own credit. Your buyers need your invoices in their GSTR-2B and your tax actually paid under Sec 16(2). Example: you file GSTR-1 by the 11th and pay ₹3 lakh output tax in cash in GSTR-3B by the 20th; your buyers' ITC is unaffected. Problems start only if you stop filing or paying.

  4. Conclusion

    1. Keep filing GSTR-1 on time.
    2. Pay output tax in cash if credit is blocked.
    3. File GSTR-3B on time.
    4. Reassure key customers if they ask.

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