Answer

GST

Exporter's refund stuck due to block

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  1. Facts

    Rule 86A also stops use of blocked credit for claiming a refund of unutilised credit. You need the block lifted, at least for the refund amount, before the refund can be processed.

  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
    • Rule 86A(2), CGST Rules 2017Debit may be allowed again, fully or partly, once the officer is satisfied
    • Sec 54, CGST Act 2017Refund of tax, including unutilised ITC on zero-rated supplies
  3. Analysis

    Rule 86A(1) bars debit for 'claim of any refund of any unutilised amount'. Sec 54 refunds have a two-year time limit, so the block can put your claim at risk if it drags on. Example: ₹15 lakh refund claim with ₹10 lakh blocked; ask for release with export evidence, and keep track of the two-year limit.

  4. Conclusion

    1. Check the relevant date and two-year refund deadline.
    2. Ask for release with export and purchase evidence.
    3. File the refund for the unblocked part if possible.
    4. Escalate if the block threatens the time limit.

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